Financial Crime Prevention Policy

Our Financial Crime Prevention Policy is in accordance with the regulatory requirements of the Royal Institution of Chartered Surveyors (RICS). 

Purpose and Scope

This policy sets out the organisation’s commitment to preventing, detecting, and responding to bribery, corruption, money laundering, terrorist financing, and sanctions violations. It applies to all activities undertaken by the business and to any third parties acting on its behalf.

Policy Statement

The organisation operates a zero tolerance approach to financial crime. Integrity, transparency, and professional conduct are expected at all times. No commercial pressure or client instruction justifies breaching this policy or any applicable law. The organisation is committed to maintaining proportionate, risk based controls and ensuring that its services are not used for illicit purposes.

Governance and Responsibilities

All responsibilities described in this policy are carried out personally by the Principal, being the Director of the company at any given time, who also fulfils the role of Money Laundering Reporting Officer. The Principal is responsible for oversight, decision making, compliance, reporting, and ensuring that all obligations under relevant legislation and professional standards are met.

Risk Assessment

The business undertakes regular assessments of financial crime risks relevant to its services, clients, geographic exposure, and delivery channels. These assessments inform the controls and due diligence measures applied.

Anti Bribery and Anti Corruption

Bribery and corruption in any form are prohibited. This includes offering, giving, requesting, or accepting anything of value intended to improperly influence a decision or secure an advantage. Gifts and hospitality must be reasonable, proportionate, transparent, and never intended to influence professional judgement. Any such items are recorded appropriately. Third parties acting on behalf of the business must operate to equivalent anti bribery standards, and any engagement with intermediaries must be transparent and legitimate.

Anti Money Laundering and Counter Terrorist Financing

Client due diligence is conducted before entering into a business relationship or carrying out relevant work. This includes verifying identity, understanding beneficial ownership, and assessing the purpose and nature of the engagement. Enhanced due diligence is applied where higher risks are identified. Ongoing monitoring ensures that client information remains current and that activity is consistent with expectations. Suspicious activity is assessed by the Principal in their capacity as MLRO, and reports are made to the National Crime Agency where required.

Sanctions Compliance

The business does not engage with individuals, entities, or jurisdictions subject to sanctions. Clients, beneficial owners, and relevant third parties are screened against applicable sanctions lists, and any potential matches are investigated before proceeding.

Record Keeping

Records relating to due diligence, risk assessments, monitoring, training, and suspicious activity reports are maintained securely and retained for the legally required period. Records must be accurate, complete, and available for regulatory inspection.

Training and Awareness

The Principal maintains up to date knowledge of financial crime obligations, relevant legislation, and professional standards. Training needs are reviewed periodically to ensure ongoing compliance.

Third Party Management

Any contractors, agents, or service providers engaged by the business must operate to standards consistent with this policy. Appropriate due diligence is undertaken before engagement, and contractual terms include obligations relating to financial crime prevention.

Monitoring and Review

The effectiveness of this policy and the associated controls is reviewed regularly. Updates are made where necessary to reflect changes in legislation, regulation, or professional standards.

Reporting Concerns

Any concerns relating to financial crime, whether arising from client activity or third party behaviour, must be escalated to the Principal immediately. The business supports open reporting and does not tolerate retaliation against individuals raising concerns in good faith.

Disciplinary and Legal Consequences

Breaches of this policy may result in termination of client relationships, termination of third party engagements, and reporting to regulatory or law enforcement authorities. Criminal or civil penalties may also apply.

Approval

This policy is approved and adopted by the Principal.