Public-facing policy
Document owner: North Cheshire Property Management Limited
Version: 1.0 | Effective date: 12 August 2026 | Review: At least annually and when legislation, services or risk materially change
1. Purpose
North Cheshire Property Management Limited (NCPM) is committed to preventing its business and the property sector from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion or other financial crime. NCPM applies a proportionate, risk-based approach to customer due diligence (CDD), record keeping, monitoring and escalation.
2. Scope
This policy applies to NCPM’s residential and commercial property management, letting and estate agency activities, and to directors, employees, contractors and agents involved in relevant activities.
3. Legal and regulatory framework
Where applicable, NCPM complies with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, relevant HM Revenue & Customs (HMRC) guidance, UK financial sanctions requirements and applicable legislation relating to suspicious activity reporting.
4. When statutory CDD applies
Estate agency work involving the sale or purchase of property is subject to the relevant AML requirements. Letting agency work is within the AML regime where an agreement is concluded for a term of one month or more and the monthly rent is, or is equivalent to, £10,000 or more. NCPM will apply CDD to both relevant landlords and tenants where a letting is within scope. The £10,000 threshold applies from 30 June 2026.
NCPM may also undertake identity, ownership, sanctions, source-of-funds or other checks outside the statutory threshold where its risk assessment indicates that this is appropriate.
5. Customer due diligence
- Verify identity using reliable documentary and/or electronic methods.
- Establish the purpose and intended nature of the business relationship or transaction.
- Identify and, where required, verify beneficial owners and persons acting on behalf of customers.
- Obtain information about source of funds and, where appropriate, source of wealth.
- Apply enhanced due diligence where a higher risk is identified.
- Keep appropriate records and review information where required.
6. Companies, partnerships and other entities
Where a customer is a company, partnership, trust or other legal entity, NCPM may obtain incorporation/registration details, registered office information, directors or controlling persons, ownership information and details of beneficial owners. The level of information requested will depend on the entity and risk.
7. PEPs and sanctions
NCPM has systems and procedures to identify politically exposed persons (PEPs), family members and known close associates where required. A PEP relationship is not automatically prohibited, but enhanced due diligence and appropriate senior-management approval will be applied where required. Sanctions screening may also be undertaken on relevant parties.
8. Source of funds and wealth
NCPM may request evidence explaining how a transaction, rent, deposit or other payment is funded. This may be particularly relevant to large or unusual payments, third-party payments, significant upfront payments, overseas funds, complex structures or other higher-risk circumstances.
9. Suspicion and refusal to provide information
If information cannot be satisfactorily verified, or a transaction presents concerns that cannot be appropriately mitigated, NCPM may decline to proceed or may pause the transaction or relationship. Where required, NCPM will consider whether a Suspicious Activity Report (SAR) should be made to the National Crime Agency. NCPM will not disclose information where doing so would amount to unlawful tipping off.
10. Data protection and records
AML information will be handled securely and in accordance with applicable data protection requirements. Records will be retained for the period required by law and securely disposed of when no longer required.
11. Service provider
NCPM may use an appropriately selected external identity-verification or AML service provider. No specific provider is appointed under this policy. Any provider used will operate under appropriate contractual and data-protection arrangements.
12. Review
This policy will be reviewed at least annually and sooner where there is a material change in legislation, services, business structure, technology or risk.
