AVIVA REALTY LTD is committed to full compliance with the UK’s Anti-Money Laundering (AML) laws and regulations. We have a zero-tolerance approach to money laundering, terrorist financing, and any activity that facilitates criminal or terrorist conduct.
This policy outlines the procedures we follow to prevent our services from being used for illicit financial activity in line with the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended).
To detect and prevent money laundering and terrorist financing.
To comply with the UK legal and regulatory requirements.
To protect the company’s integrity, reputation, and investor trust.
To establish procedures for risk-based customer due diligence (CDD), enhanced due diligence (EDD), and ongoing monitoring.
Money Laundering Reporting Officer (MLRO):
A senior employee is designated as the MLRO to oversee compliance and reporting obligations.
All Employees:
Must complete AML training, conduct due diligence, and report suspicious activity to the MLRO without delay.
Before entering any business relationship, we will:
Identify and verify the identity of all individual clients using government-issued ID.
Collect proof of address (recent utility bill, bank statement, etc.).
For corporate clients: identify and verify directors and Ultimate Beneficial Owners (UBOs).
Assess the source of funds and purpose of the investment.
EDD is applied in high-risk cases, including:
Politically Exposed Persons (PEPs)
High-risk countries
Unusual or complex transactions
Large cash investments
EDD may include:
Additional identity verification
Evidence of source of wealth
Senior management approval
Monitor client transactions for consistency with stated investment purposes.
Periodically review and update client information.
Flag and investigate unusual patterns or inconsistencies.
We maintain AML records for a minimum of 5 years from the end of the client relationship, including:
Identity and verification documents
Transaction history
Internal and external reports (e.g. SARs)
Employees must report any suspicious activity to the MLRO.
The MLRO will evaluate and, if appropriate, submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
All relevant staff will undergo regular AML training to stay updated on regulations, risks, and reporting responsibilities.
This policy is reviewed annually or in response to legal/regulatory changes to ensure ongoing compliance.