Anti Money Laundering Policy

- Updated 2nd March 2024

It is the policy of Neilson & Bauer that all members of staff at all levels shall actively participate in preventing the services of Neilson & Bauer from being exploited by criminals and terrorists for money laundering purposes. This participation has its objectives:

  • Ensuring Neilson & Bauer's compliance with all applicable laws, statutory instruments of regulation, and requirements of Neilson & Bauer's supervisory authority (HMRC)
  • Protecting Neilson & Bauer and all its staff as individuals from the risks associated with breaches of the law, regulations and supervisory requirements
  • Preserving the good name of Neilson & Bauer against the risk of reputational damage presented by implication in money laundering and terrorist financing activities

Making a positive contribution to the fight against crime and terrorism. To achieve these objectives, it is the policy of Neilson & Bauer that:

  • Neither commercial considerations nor a sense of loyalty to clients shall be permitted to take precedence over Neilson & Bauer’s anti-money laundering commitment
  • Neilson & Bauer have appointed two directors to be responsible for anti-money laundering compliance (MLRO and a MLCO). Neilson & Bauer have notified the supervisory authority and supplied the name of the responsible director
  • Neilson & Bauer have appointed a Money Laundering Reporting Officer (MLRO) and informed the supervisory authority of their name. The MLRO shall be afforded every assistance and co-operation by all members of staff in carrying out the duties of their appointments
  • Neilson & Bauer have carried out a business-wide assessment of the risks of money laundering and terrorist financing to which Neilson & Bauer is subject, and have designed and implemented appropriate controls to mitigate and manage effectively the risks identified. 
  • Neilson & Bauer have established and maintained documented, proportionate policies and procedures including controls, which outline the positive actions to be taken by staff to prevent money laundering and terrorist financing in the course of their work. The MLRO shall keep these under review to ensure their continuing appropriateness.
  • To comply with HMRC’s regulations, all Neilson & Bauer staff are regularly and continually trained on Money Laundering/Terrorist Financing/Criminal Finances Act.
  • All staff will be regularly updated with latest sanctions 
  • Documentary evidence is required for all Vendors and Purchasers and supporting guarantors or giftors. Evidence is also required from all Landlords and tenants renting at over Euro 10,000 per month . Production of original documents is the preferred option, however we can accept certified copies and pdf’s in some instances. We require proof of ownership for all landlords

Below is a list of acceptable documents (for individuals), and where and how, these can be certified:

  • Passport
  • Photo-Card Driving Licence - can be used as photo-id or proof of address – not both
  • National ID Card
  • Council Tax Demand
  • Utility Bill – no more than 3 months’ old (MOBILE PHONE BILLS ARE NOT ACCEPTABLE)
  • CURRENT Bank Statement or Credit Card Statement can be accepted; only if issued by a regulated financial sector firm in the UK or the EU (if online document it must be a PDF)

Below is a list of people who can certify your documents:

  • bank or building society official
  • councillor
  • minister of religion
  • dentist/doctor
  • chartered accountant
  • solicitor or notary
  • teacher or lecturer
  • Post Office

The person you ask must not be:

  • related to you
  • living at the same address
  • in a relationship with you

The certification should be as follows:

The third party must have seen the original and must write above their signature that the copy is a true replica of the original and (if applicable) that the photograph bears a true likeness. They must print their name, state their capacity, contact details and the date of signature. A company stamp is desirable, but not essential, unless from a solicitor’s or accountancy practice. The solicitor should also print their name and SRA number.

Deposits and/or Financial Gifts and mortgage finance:

We have a legal obligation to trace and verify the ORIGIN/SOURCE of all deposits and/or financial “gifts”, as well as verifying the identity of all those providing the gift.

We have a legal obligation to verify the source of all finance being used to complete a proposed purchase and monitor and veriphy any changes during the purchase.

We require documentation of any mortgage agreement in principle.

We are required to verify any finance being provided by UK trusts and off-shore trusts or company purchases.

We check each buyer to establish if there a buyer and or person associated with any sale of purchase is a PEP (politically exposed person).

We endeavour to stay up to date with all Sanctions as listed by HM Govt.