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Money Laundering Checks

Brisk Buyers are subject to the Money Laundering Regulations 2017. This means that we have to obtain and hold identification and proof of address for all clients. Additionally, we are also required to establish whether there are any beneficial owners on whose behalf the transaction or activity is taking place, hence, we would request you to identify anyone who you would consider to be a beneficial owner. Where appropriate, the source or destination of funds may also be requested. Without this information we will be unable to proceed with any work on your behalf.

Brisk Buyers has stringent internal controls and monitoring systems in place to satisfy themselves that their clients are not involved with criminal or fraudulent activity.

Identity Documents

Customer due diligence for Brisk Buyers involves establishing from the outset:

  • The client’s identity
  • The client’s proof of address

Brisk Buyers obtain this information by requesting clients provide certain documentation. We require sight of all original or certified documents and may arrange for a representative to meet you in person so that photographs / photocopies of documents can be carried out for our records. Once Brisk Buyers are in receipt of all necessary documents these will be analysed in more detail using fraud detection software (if required).

Below is a list of acceptable identity documents. Subject to your individual circumstances, Brisk Buyers may liaise with you for further/other documentation.

LIST A – IDENTITY DOCUMENT

  • Current signed passport
  • Valid UK driving licence
  • EEA member state identity card

LIST B – PROOF OF ADDRESS

  • UK/EU/EEA Drivers Licence (if UK Drivers Licence not used as ID) – Must be valid, not expired. Photo only. Full or provisional.
  • Bank, Building Society or Credit Union Statement – Dated with 3 months. Must include account number and show recent activity. No general correspondence.
  • Credit Card Statement – Dated within 3 months. Must include account number and show recent activity. No general correspondence.
  • UK, EU, EEA Mortgage statement – Dated within 12 months. Must show account number. No general correspondence.
  • Utility Bill – Dated within 6 months E.g. Gas, electricity, water. Must show address for service and/or account number. No general correspondence.
  • Telephone Bill – Dated within 6 months E.g. Landline or mobile pay monthly (excluding pay as you go). Must show address for service and/or account number. No general correspondence.
  • Council Tax – Dated within 12 months. Must show address for service and/or account number. No general correspondence.
  • Tenancy Agreement – Dated with 12 months. Must state full name and full property address. Issued by local council, housing association, solicitor or reputable letting agent.
  • Benefits Entitlement Letter – Dated within 12 months. Issued by DWP or Jobcentre plus. Must confirm benefit payable at time of issue. E.g. Pension, disability, single parent, housing etc.
  • HMRC Tax Notification – Dated with 6 months. Must state national insurance number and tax calculation. No general correspondence.
  • Home or Motor Insurance Certificate – Dated within 12 months. Must state insured address or registered address for vehicle and policy number. No general correspondence.
  • UK solicitors letter confirming house purchase/land registration – Dated with 3 months. Must state full name of new proprietor and full property address.
  • NHS Medical Card or letter from GP confirming registration – Dated within 3 months. Must state individual’s date of birth and NHS number. No general correspondence.
  • Official confirmation of Electoral Register entry or official poll card – Dated within 12 months. Must state full name and full address. No general correspondence.
  • Police Registration Certificate – Dated within 12 months. Must state the full residential address of the individual.

Brisk Buyers also require vendors to be photographed and provide their signatures in the presence of our Representative. Clients / property owners are to advise us if they have changed their name in the last year to assist Brisk Buyers with their check for name changes.

Probate

If you are acting as a Representative of an Estate we require the following:

  • Grant of Probate (if a will was left)
  • Letter of administration (if no will left)
  • Individual identity evidence from List A & B for the Personal Representative, either executor or administrator

Limited company

If you are acting as a Representative of a UK Company we will also require the following:

  • Certificate of Incorporation
  • Articles of Association
  • Memorandum of Association
  • Latest Annual Return or Confirmation Statement, with details of current company officers
  • If offshore, nominee director declaration and a general power of attorney
  • Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company

If you are acting as a Representative of an Offshore Company we will also require the following:

  • Certificate of Incorporation
  • Articles of Association, Memorandum of Association, Latest Annual Return with details of current company officers, Share Certificate(s) showing the Ultimate Beneficial Owner OR
  • Certificate of Incumbency
  • If the shares are owned by another company, repeat steps above for the holding company
  • Nominee director declaration and/or general Power of Attorney (if applicable)
  • Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company

Trust

If you are acting as a Representative of a Trust we require the following:

  • Trust deed
  • List of trustees
  • List of beneficiaries
  • Individual Identity evidence from List A & B for all individuals with a vest interest in 25% or more of the capital and/or those who exercise control over the Trust

Further due diligence

If Brisk Buyers has any doubts at all about a client’s identity, we won’t continue to deal with you until we are completely satisfied of your identity and if the situation presents itself we will report the individual(s) to the appropriate regulatory authorities.

Brisk Buyers as regulated property buyers will apply further due diligence measures on their clients when:

  • A transaction takes places / due to take place over 15,000 GBP
  • There is a suspicion of money laundering
  • There are doubts / suspicions about a client’s identification
  • If circumstances change with an existing client
  • If the client isn’t physically present when identification checks take place
  • When a business relationship takes place with a politically exposed person
  • There is a high risk of money laundering

Notice to property sellers

Brisk Buyers is regulated by the RICS (Royal Institution of Chartered Surveyors) and is a member of the NAPB (National Association of Property Buyers) and The Property Ombudsman. We are committed to preventing fraud in the property industry. The Quick House Sale industry unfortunately has become targeted by fraudulent sellers of late and it’s for this reason why Brisk Buyers are cautious and vigorous at the same time in establishing the identities of their clients.

Brisk Buyers is committed to combating Money Laundering and the prevention of fraud and identity theft. The main legislation governing money laundering is the Proceeds of Crime Act 2002, and abiding to this legislation, Brisk Buyers undertake physical and documentary checks to prove homeowners identity and proof of residence. The ultimate reason for doing this is to protect the Brisk Buyers brand, business and the general public.

If clients of Brisk Buyers decide not to choose a lawyer recommended by us, Brisk Buyers will subsequently then have to undertake due diligence checks on your legal representative. If Brisk Buyers suspect any sign of fraudulent activity there will be no hesitation to report the offence to our Money Laundering Regulatory Officer (MLRO) and in turn the National Crime Agency.

A warning to potential fraudsters

Brisk Buyers has a reputation for acquiring properties quickly and for this reason we can be targeted by fraudsters who attempt to carry out identity theft. Identity theft is generally where the property owner gives the impression that they are the property owners and then sell the property without the knowledge of the true owner.

Brisk Buyers continually train their employees on money laundering and counter fraud measures and have a good working relationship with the relevant authorities in this field. In addition to the documents we will obtain from clients, Brisk Buyers will also undertake further authentication checks in addition to the ones highlighted above.

Brisk Buyers has a relationship with the National Crime Agency and we regularly report our suspicions so that the business and the general public are protected at all times. We often report suspicions in confidence to the National Crime Agency and can still act to proceed with a potentially fraudulent purchase with a view to catching fraudsters with the appropriate authorities.

With a view to being transparent, all telephone calls are recorded for training and monitoring purposes.