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Anti-Money Laundering Policy

Anti-Money Laundering (AML) Policy

Tom Molloy Property Group Ltd, trading as Tom Molloy Estates

Last reviewed: October 2026

1. Purpose

Tom Molloy Property Group Ltd, trading as Tom Molloy Estates, is committed to preventing money laundering, terrorist financing and proliferation financing. We comply with applicable requirements under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, and other relevant legislation.

This policy sets out our approach to identifying, assessing and managing financial crime risks associated with our estate agency and, where applicable, lettings activities.

2. Our responsibilities

We maintain appropriate policies, controls and procedures to:

Assess and document the money laundering, terrorist financing and proliferation financing risks facing our business.
Carry out appropriate customer due diligence and identity verification.
Apply enhanced due diligence where required by law or where the assessed risk warrants it.
Monitor customer relationships and transactions where appropriate.
Maintain required records and provide staff with relevant AML training.
Report suspected money laundering or terrorist financing through the appropriate internal and statutory reporting channels.
Appoint a Nominated Officer to receive and assess internal reports and submit Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) where required.

We will review our procedures when legislation, official guidance or our business activities change.

3. Customer Due Diligence (CDD)

We carry out customer due diligence at the appropriate stages of a transaction or business relationship, as required by law.

Depending on the service provided and the circumstances, this may include checks on:

Buyers and sellers involved in property sales.
Landlords and tenants where our lettings activities fall within the scope of the Money Laundering Regulations.
Individuals acting on behalf of customers.
Beneficial owners and relevant individuals connected with companies, trusts or other legal arrangements.

Checks may include verifying identity, establishing the purpose and intended nature of the business relationship, identifying beneficial ownership where applicable, and assessing the source of funds or wealth where required by the circumstances and level of risk.

Identity verification may involve valid photographic identification, address information and electronic verification through a third-party provider, including Landmark, where appropriate.

The documents and checks required will depend on the customer, the transaction and the assessed risk. Additional information may be requested where necessary.

We will not proceed with a relevant business relationship or transaction where we cannot complete the legally required due diligence, subject to applicable legal requirements.

4. Enhanced Due Diligence (EDD)

We apply enhanced due diligence where required by the Money Laundering Regulations and where a higher level of risk is identified.

Relevant risk factors may include:

A customer or beneficial owner who is a Politically Exposed Person (PEP), or a family member or known close associate of a PEP.
Involvement with a high-risk third country or a jurisdiction presenting elevated financial crime risks.
Complex or unusual ownership arrangements.
Unexplained third-party involvement or unusual funding arrangements.
Inconsistencies in customer information or documentation.
Remote or non-face-to-face dealings that present additional identity verification risks.
Other circumstances indicating an increased risk of money laundering, terrorist financing or proliferation financing.

Additional measures may include further identity checks, obtaining information about the source of funds or wealth, senior management approval where required, and enhanced ongoing monitoring.

5. Ongoing Monitoring

Where required, we monitor business relationships to ensure that customer information and activity remain consistent with our understanding of the customer and the purpose of the relationship.

We consider changes in circumstances, unusual activity, concerns about the source of funds, and other relevant risk indicators.

Where new information raises concerns, we may request further information, carry out additional checks, suspend relevant activity where appropriate, or consider whether a report is required.

6. Suspicious Activity Reporting

All staff must promptly report any knowledge or suspicion of money laundering, terrorist financing or other relevant suspicious activity to the Nominated Officer.

Examples of potential warning signs include:

Reluctance to provide required identification or supporting information.
Unexplained sources of funds or wealth.
Unusual payment arrangements or unnecessary third-party involvement.
Inconsistent or potentially fraudulent documents.
Unexplained ownership structures or reluctance to identify beneficial owners.
A transaction that appears inconsistent with the customer's known circumstances.

The Nominated Officer will assess internal reports and determine whether a SAR should be submitted to the NCA, in accordance with applicable law.

Staff must not disclose information in a way that could constitute unlawful tipping off or prejudice an investigation.

7. Record Keeping

We maintain records of customer due diligence, relevant risk assessments, business relationships and transactions, internal reporting, staff training and other required compliance activities.

Records will generally be retained for five years from the end of the business relationship or, for an occasional transaction, from the date the transaction is completed, as applicable under the Money Laundering Regulations.

At the end of the applicable retention period, records will be securely deleted unless a legal requirement or other lawful basis requires them to be retained for longer.

Where a third-party provider, such as Landmark, processes or retains information independently, its handling of that information is also subject to its applicable privacy notice and contractual arrangements.

8. Staff Training and Responsibilities

Relevant staff will receive appropriate AML training to help them understand their responsibilities, recognise warning signs, follow customer verification procedures and escalate concerns promptly.

The Nominated Officer is responsible for overseeing internal AML reporting and compliance procedures. All staff are responsible for following this policy and raising concerns without delay.

9. Nominated Officer

Name: Tom Molloy
Position: Managing Director
Email: info@tommolloy.co.uk
Telephone: 0121 798 1378

The Nominated Officer receives and assesses internal suspicious activity reports and submits reports to the NCA where required.

10. Review and Risk Assessment

This policy will be reviewed at least annually and whenever there are material changes to our business activities, relevant legislation or official guidance.

The company maintains a separate written business risk assessment and supporting procedures to identify and manage the risks relevant to its services.