The UK’s KYC and anti-money laundering (AML) requirements are governed by:
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, amended in 2019 and 2022.
Enforced by regulatory bodies like HMRC, FCA (Financial Conduct Authority), and NCA (National Crime Agency).
As a property sourcing and investment company, AVIVA REALTY LTD must:
Identify and verify the identity of all individual clients (name, address, date of birth).
Verify source of funds/wealth, especially for high-value or overseas transactions.
Identify ultimate beneficial owners (UBOs) for corporate clients.
Conduct Enhanced Due Diligence (EDD) for:
High-net-worth individuals (HNWI)
Politically exposed persons (PEPs)
Clients from high-risk countries
Individuals:
Passport or photo driving licence (proof of identity)
Utility bill or bank statement (proof of address – less than 3 months old)
Companies/Trusts:
Certificate of incorporation
Proof of registered address
Details of directors/shareholders
UBO declaration
Records must be kept for at least 5 years after the end of the business relationship.
Regularly update client information and re-check documents if any risk flags appear.
Any suspicious activity must be reported via a Suspicious Activity Report (SAR) to the NCA.
HMRC or FCA can impose hefty fines, revoke licenses, or pursue criminal prosecution.
Firms must train staff regularly and maintain a robust AML/KYC compliance policy.