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AML Policy & Procedure Addendum.

AML Policy & Procedure Addendum.

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Description:

The addendum was produced following the recent update to the National Risk Assessment and HMRC guidance which highlighted certain areas of potential risk to be aware of as well as a number of countries that have individual risks that you may come across as an Estate Agency Business. The only changes to the regulations in this latest update are detailed on the addendum and this includes the change to the definition of ‘Super-Prime’. A super Prime property will now be considered as Super-Prime if it exceeds £5m in London and the South-East or £1m elsewhere in the UK rather than the top 5% in your area. The countries detailed in Table A do not necessarily mean that we are obliged to carry out EDD, however, you should take a risk-based approach and consider EDD if relevant.