Anti-Money Laundering (AML) Policy

1. Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to ensure that THE PLAYERS PROPERTY PARTNERS LIMITED complies with the UK Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), as amended, and any other relevant legislation, including the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000. Our aim is to prevent the business from being used for money laundering, terrorist financing, or other financial crimes.

2. Scope

This policy applies to all employees, directors, agents, and third-party contractors associated with THE PLAYERS PROPERTY PARTNERS LIMITED. All employees must be aware of their responsibilities and obligations under this policy and UK law to detect, prevent, and report money laundering and terrorist financing activities.

3. Definition of Money Laundering

Money laundering is defined as the process of making illegally-gained proceeds appear legal. Under the MLR 2017 and POCA, money laundering involves the following stages:

• Placement: Introducing illegal funds into the financial system.
• Layering: Obscuring the origins of these funds through complex transactions.
• Integration: Reintroducing the now-laundered money into the economy.

4. Risk-Based Approach

THE PLAYERS PROPERTY PARTNERS LIMITED adopts a risk-based approach to AML compliance, as required by the MLR 2017. We conduct regular risk assessments to identify and assess the risks of money laundering and terrorist financing that our business may face. These assessments consider:

• Customer risk factors (e.g., customers from high-risk countries, politically exposed persons).
• Transaction risk factors (e.g., large transactions, unusual payment methods).
• Geographic risk factors (e.g., customers or transactions involving high-risk jurisdictions).

5. Customer Due Diligence (CDD)

In compliance with MLR 2017, THE PLAYERS PROPERTY PARTNERS LIMITED undertakes Customer Due Diligence (CDD) before establishing a business relationship, conducting a transaction over £10,000, or when there is suspicion of money laundering or terrorist financing.

The steps include:

• Identifying the customer and, where applicable, beneficial owners by obtaining reliable, independent source documents, data, or information (e.g., passport, utility bills).
• Understanding the nature and purpose of the business relationship.
• Ongoing monitoring of the business relationship, including scrutinising transactions to ensure they are consistent with our knowledge of the customer and their risk profile.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) is applied in higher-risk situations, such as dealing with Politically Exposed Persons (PEPs) or customers from high-risk third countries. EDD may involve obtaining additional identification documents, understanding the source of funds and wealth, and applying more frequent and thorough monitoring measures.

7. Record Keeping

In accordance with MLR 2017, we will keep records of all CDD information, transactions, and business correspondence for a minimum of five years after the end of the business relationship or the date of the transaction. Records will be kept in a secure, retrievable format and will be made available to competent authorities such as the FCA or HMRC upon request.

8. Reporting Suspicious Activity

All employees are required to report any suspicious activity or transactions to the designated Money Laundering Reporting Officer (MLRO). The MLRO is responsible for:

• Evaluating internal reports of suspicious activity.
• Submitting a Suspicious Activity Report (SAR) to the UK’s National Crime Agency (NCA) where there is knowledge or suspicion of money laundering or terrorist financing.
• Keeping comprehensive records of all SARs and any subsequent actions taken.

9. Employee Training

THE PLAYERS PROPERTY PARTNERS LIMITED provides regular and ongoing AML training to all employees to ensure they understand the UK’s AML laws, recognize signs of potential money laundering and terrorist financing, and know how to report suspicious activities internally.

10. Internal Controls and Compliance Monitoring

We have established internal controls and monitoring systems to ensure ongoing compliance with the MLR 2017 and other applicable laws. This includes:

• Regular audits of AML processes and controls.
• Independent testing of AML programs.
• Reviewing and updating this policy annually or as required.

11. Penalties for Non-Compliance

Failure to comply with this AML Policy or UK AML regulations may result in disciplinary action, including termination of employment or contract. Noncompliance may also expose individuals and the company to severe civil and criminal penalties.

12. Policy Review

This policy will be reviewed annually, or sooner if there are significant changes in UK AML laws and regulations, to ensure its effectiveness and relevance.

13. Contact Information

For any questions or concerns about this AML Policy or to report suspicious activity, please contact the MLRO: