AML
Compliance
This policy statement was last updated on [22/07/2025].

Burtons Property Ltd

Anti-Money Laundering (AML) Policy Statement

Overview

Burtons Property Ltd is committed to upholding the highest standards of integrity and ethics in all areas of its business. We maintain a zero-tolerance stance on money laundering and the handling of criminal proceeds. We actively implement robust controls and measures to prevent our business and services from being exploited for unlawful purposes.

In line with the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Money Laundering Regulations 2007, we have established internal systems designed to prevent misuse of our operations for money laundering activities.

Although Burtons Property Ltd is not currently subject to registration requirements under the Money Laundering Regulations, we regularly monitor our operations to ensure compliance thresholds are not inadvertently exceeded.

Who Must Comply with This Policy

This policy applies to:

All Burtons Property Ltd staff—both permanent and temporary.
Contractors and third-party service providers engaged by the company.

Additionally, we expect our partners and suppliers to uphold standards equivalent to those outlined in this policy.

Everyone has a role to play. Failing to act on known or suspected money laundering may be considered an offence.

Understanding Money Laundering

Money laundering refers to the act of disguising the origins of illegally obtained money, typically through a series of transactions that make the funds appear legitimate. It typically occurs in three key stages:

Placement: Illegally obtained funds are introduced into the financial system.
Layering: Transactions are conducted to obscure the origin of the funds.
Integration: The laundered money is integrated into the legitimate economy, often through refunds, property deals, or investments.

A real-world scenario that may impact Burtons Property Ltd might involve someone paying rent or a deposit in cash (placement), withdrawing or cancelling the transaction shortly after (layering), and receiving the money back through legitimate means (integration).

Identifying Red Flags

Employees handling payments or customer interactions must remain vigilant for potentially suspicious behaviours. Warning signs may include:

Customers attempting to pay in large amounts of cash.
Receiving overpayments followed by refund requests—especially where refunds are requested via cheque.
An unusually low offer for goods or services.
Difficulties verifying the identity of a customer or supplier.
Individuals reluctant to provide identification or justification for using services.
The involvement of intermediaries without a clear reason.
Unusual or inconsistent patterns of transactions.
Transactions that don’t align with the customer’s known business profile.

Handling Cash Payments

Burtons Property Ltd must register with HMRC if it accepts or makes cash payments of €10,000 or more (or equivalent in other currencies). This applies whether the payment is made directly to our account or via a third party on our behalf.

This includes:

Single transactions in excess of €10,000.
Multiple linked cash payments totalling €10,000 or more.
Apparent attempts to divide large cash payments into smaller sums to avoid reporting obligations.

Internal Procedures

To safeguard against involvement in money laundering, Burtons Property Ltd follows these key procedures:

Customer and Supplier Due Diligence
We verify and document the identity of clients and third parties before entering into business relationships.
Transaction Records
All records related to financial transactions and identity verification are retained for a minimum of seven years after the business relationship ends.
Staff Awareness and Reporting Obligations
Employees involved in financial handling must remain alert to suspicious behaviours and report any concerns promptly.
Cash Payment Policy
Any cash payment exceeding €10,000 must be refused. Customers should instead be asked to use bank transfers, debit or credit cards, solicitors' cheques, or bank drafts.
Reporting Suspicious Activity
Any suspicions must be reported immediately to a relevant manager or via the Speak-Up Helpline (0800 297 0110). If you suspect money laundering, do not discuss it with others, as this may prejudice an investigation.

Consequences of Non-Compliance

Failing to report a suspicion of money laundering is a criminal offence, with serious legal implications. There are very limited exceptions where failure to report is justified under the law.

Disregarding the procedures outlined in this policy, especially failing to report red flags, may result in disciplinary action and possible prosecution.

While the risk of Burtons Property Ltd being used for money laundering is considered low, every employee must understand the seriousness of this issue and how to escalate concerns appropriately.