Anti-Money Laundering (AML) Policy and Procedures for Property Service Providers
We, O Sullivan Mc Goldrick Property Plus, have the following AML procedures in place:
Customer Due Diligence (CDD)
As a provider of property services, Customer Due Diligence is compulsory. The following documents are required for each transaction, where the client is a:
Individual – Photo ID (Passport, Full Drivers Licence, National Identity Card, Social Welfare Card with photo, National Age card….) – Non – Photo Verification (Revenue Commissioners Letter with PPSN, Dept of Social Protection letter with PPSN, Utility Bill, Medical Card….)
Corporate Clients – This also covers Receivers – Memorandum and Articles of Association – List of Directors names – Verify identity of one director and one signatory (as for individual) – Beneficial Owners identity can be verified via clients’ solicitor
Trusts – Copy of Trust Deed – Full name of Trust – Nature and purpose of Trust – Country of establishment – Names of all Trustees and name and address of any protector/settler – Verify the identity of one Trustee and one signatory as for individual
Partnerships – Obtain a copy of Partnership agreement – Verify the identity of one Partner and one signatory as for individual
Where a client refuses or cannot comply with the requirements of Customer Due Diligence, the Property Service Provider (PSP), must cease the provision of the property services.
Records are maintained on file, regarding CDD of all clients for each transaction for 5 years.
Suspicions relating to ownership of property to be confirmed with the Property Registration Authority.
As a good practice measure, CDD for the purchaser/Lessee may also be undertaken. Suspicious Transaction Reports (STR’s)
The threshold for the amount of cash which can be accepted, without making a Suspicious Transaction Report (STR) is zero.
Any cash received, unless where the PSP is absolutely satisfied as to its bona fides, or where the PSP has cause for concern relating to the client or purchaser, must be considered as suspicious and a Suspicious Transaction Report (STR) completed and forwarded to the Gardaí and Revenue. Training
AML training to be undertaken annually as part of the PSRA CPD programme.
Our AML Policy Officer is Jonathan Mc Goldrick, Licence no 002395-003297.