Staurus Properties Limited
Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) Policy
AML Registration Number: XCML00000198864
Version Control
Version: 2.1
Effective Date: 18/07/2025
Reviewed Date: 18/07/2025
Next Review Date: 18/07/2026
1. Purpose & Scope
Staurus Properties Limited is fully committed to preventing money laundering and terrorism financing across all business activities. This policy outlines our compliance procedures in line with:
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Proceeds of Crime Act 2002 (POCA)
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Terrorism Act 2000
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Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended)
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Financial Action Task Force (FATF) Recommendations
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2025 UK National Risk Assessment (NRA)
This policy applies to all employees, consultants, contractors, and third parties representing Staurus Properties Limited.
2. Responsibilities
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Board of Directors & Senior Management: Oversee implementation and enforcement of AML/CFT controls.
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Money Laundering Reporting Officer (MLRO): Leads AML compliance, conducts risk assessments, receives internal reports, and files Suspicious Activity Reports (SARs) with the National Crime Agency (NCA).
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Employees & Consultants: Must adhere to AML protocols, complete mandatory training, and report suspicious activity.
3. Customer Due Diligence (CDD)
We implement a risk-based approach to verifying all clients:
Individual Clients:
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Government-issued photo ID (passport or driving licence)
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Proof of address (within 3 months)
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Source of Funds (SOF) declaration for high-value transactions
Corporate Clients:
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Certificate of Incorporation
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Proof of registered office
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Names and addresses of Directors and Shareholders
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Ultimate Beneficial Owner (UBO) verification
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Evidence of Source of Funds (bank statements, company accounts)
Types of CDD:
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Standard CDD: For most UK-based individuals
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Enhanced Due Diligence (EDD): For high-risk clients, PEPs, or clients from high-risk jurisdictions
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Ongoing Monitoring: Routine checks on transactions and updates on client risk status
4. Risk-Based Approach
Clients and transactions are categorised as:
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Low Risk: UK-based individuals/entities with a transparent financial background
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Medium Risk: Clients with complex structures or from FATF grey-listed countries
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High Risk: PEPs, high-cash transactions, clients from high-risk third countries, or non-transparent sources of funds
Higher-risk clients require EDD, approval by senior management, and closer transaction monitoring.
5. Suspicious Activity Reporting
Red flags that must be reported to the MLRO include:
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Third-party payments
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Reluctance to provide documentation
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Use of offshore accounts or entities with no apparent connection to the transaction
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Large or unusual cash deposits
The MLRO will determine if a SAR must be filed with the NCA.
6. Record-Keeping
We retain all AML-related documents and data for a minimum of five years, including:
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Client ID verification
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Source of funds evidence
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SARs and internal reports
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Transaction records
7. Training & Awareness
Mandatory annual AML/CFT training is required for all staff and consultants. Training modules include:
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Legislative and regulatory obligations
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Risk indicators and typologies
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How to report suspicious behaviour
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Consequences of non-compliance
8. Penalties for Non-Compliance
Breach of AML/CFT obligations may result in:
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Disciplinary action, including termination
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Regulatory sanctions
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Criminal prosecution, fines, or imprisonment
9. Review & Updates
This policy will be reviewed:
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Annually; or
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Following significant legislative updates (e.g., National Risk Assessment changes or FATF revisions)
All amendments will be communicated to staff and integrated into Zoho CRM and training materials.
10. Compliance Obligation Schedule
| Compliance Area | Obligation | Frequency | Responsible Party |
|---|---|---|---|
| Customer Due Diligence (CDD) | Verify identity and address for all clients | Ongoing | MLRO & Compliance Team |
| Enhanced Due Diligence (EDD) | Apply advanced checks for high-risk clients | As required | MLRO |
| Ongoing Monitoring | Review transactions and behaviours | Ongoing | Compliance Team |
| Record-Keeping | Store all documentation for at least 5 years | Ongoing | Compliance Officer |
| Training & Awareness | Deliver AML/CFT training annually | Annually | HR & Compliance Team |
| Suspicious Activity Reports | File SARs to NCA if necessary | As required | MLRO |
| Policy Review & Updates | Reflect legislative changes and operational updates | Annually | MLRO |
| Internal Audits | Audit AML processes, especially client onboarding and documentation | Quarterly | Compliance Officer |
For questions or further information, contact the MLRO at:
Email: mlro@staurusproperties.com
Policy Updated: 18/07/2025