Anti Money Laundering Policy

Our Anti Money Laundering (AML) Policy

TEGRE Limited trading as Exclusively Group Real Estate Anti-Money Laundering Policy Statement.

We are committed to ensuring that we have adequate controls in preventing money laundering activities and terrorist financing, in line with the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017.

Risk-based policies and procedures have been established to anticipate and prevent money laundering and terrorist financing within our business.

A risk-sensitive and risk-based approach are how our business assess the risk of a customer(s) laundering money through our business.

Our business takes the starting point that most customers will not launder money, however through our risk assessments and internal proceeds we may identify criteria that would indicate a higher risk of money laundering or money laundering. This, for example, could be where there is no face-to-face meeting to establish the identity of a customer(s) and we have to use reliance on a third party to identify that customer or the customer is a politically exposed person. There are many scenarios where a customer could arouse suspicion and lead us to have to carry out further due diligence.

Ultimately if the risk of money laundering or terrorist financing is apparent, we have to report this to the National Crime Agency (NCA) by submitting a Suspicious Activity Report (SRA) via our nominated officer.

How We Manage the Risks- 
In short, we are committed to ongoing staff training in anti-money laundering legislation.

We identify all our client(s) and customer(s) by collecting a series of documents to prove the customer's identity and address. When a vendor(s) or the buyer(s) is entering into a business transaction with us we will request predefined documents that we use to identify that individual or business.
We use risk assessments to identify the level of due diligence that we carry out on an individual. If the transaction proves to be a high risk then enhanced due diligence will take place. This means we will need further documentation from the individual and the transaction will be looked at and monitored in further detail with greater scrutiny.

We also use automated checks via Experian and other agents to identify individuals further and to help us verify particular documents in various circumstances that have been provided are original. This check also looks to identify if the individual is a politically exposed person or has links to a politically exposed person and checks the sanctions list to make sure we can proceed with the business relationship.

TEGRE Limited has an Anti-Money Laundering Reporting Officer whose responsibility is to give guidance, receive internal reports and make a judgement to forward a suspicious activity report (SAR) to National Crime Agency.

Money Laundering Nominated Officer- Jinny Walker