Esper Investments Ltd – Anti Money Laundering Policy

Risk Assessment
Esper Investments Ltd (referred to as the Company) acts as a property sales agent that works with investors who wish to buy property from developers in the UK. Our business falls under the
scope of Estate Agencies and as such we need to register for AML and have clear policies and procedures in place to prevent clients laundering money from illegal sources.

The company understands that property is a high risk activity. This is due to the high value transaction sizes, which allow for considerable amounts of illegal money to enter into the UK financial system.

AML Policies, Controls and Procedures
1/ The Company understands and accepts our responsibility to act as a gatekeeper to prevent illegal funds from being laundered through us directly, or through our partners.

2/ If clients send money to us directly we will ask for a copy of the client’s passport in addition to proof of address, and the source of funds. We are unlikely to receive direct payment from any investors who are based overseas.

3/ Our company doesn’t accept cash.

4/ The Company will actively sell property for investment purposes. There is likely to be significant interest from both UK and overseas investors who want to buy into the UK property market. There is a risk of clients wanting to buy property with the purpose of laundering money. Clients who are buying property will pay a reservation deposit (typically £5,000) to the developer directly and not to us. The rest of the funds will be sent to a UK lawyer who is representing them in the purchase of a property. All lawyers have strict AML procedures in place. However, the Company understands that if we suspect any suspicious activity we need to submit a Suspicious Activity Report and also inform the client’s lawyers of our concerns.

5/ We receive remuneration from developers once the client has Exchanged Contracts. At this point the property lawyers have already completed AML checks on the client.

6/ We will not engage in business with any prospective client who lives or has interests in a country on the UK sanctions list.

7/ The Company director (Robert David Herring) will personally oversee any payments into the Company. He has worked for banks and other financial institutions and fully understands his responsibilities in performing AML checks.

8/ The Company understands that its business can evolve. As such, we will monitor our AML Policies, Controls and Procedures to ensure they manage risk and to fulfill our obligations of fighting financial crime.