Anti-Money Laundering Policy

1. Policy Statement

1.1. Britestate Ltd is committed to preventing the use of its platform for money laundering and terrorist financing. This policy sets out our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”), the Proceeds of Crime Act 2002 (“POCA”), the Terrorism Act 2000, and the Sanctions and Anti-Money Laundering Act 2018.

1.2. Britestate is registered with HMRC for AML supervision. Our registration reference is [HMRC REFERENCE].

2. What AML Means for You

2.1. As a platform facilitating property transactions, we are required by law to conduct checks on users involved in those transactions. This is to prevent the platform from being used to launder the proceeds of crime or to finance terrorism.

2.2. AML requirements apply to users who are conducting or facilitating property transactions through the platform — including buyers, sellers, landlords, and estate agents. General browsing and property searching do not trigger AML checks.

2.3. We apply a risk-based approach. The level of verification required will depend on the nature and value of the transaction, the type of user, and any risk factors identified during our assessment.

3. Customer Due Diligence

3.1. Before establishing a business relationship or facilitating a transaction, we may require you to provide: proof of identity (full legal name, date of birth, residential address); proof of the source of funds for the transaction; and, for corporate entities, details of beneficial owners (individuals owning or controlling more than 25%).

3.2. We may use technology-assisted identity verification, including document checks and biometric verification, provided by regulated third-party providers.

3.3. We cannot proceed with a business relationship or transaction where customer due diligence cannot be satisfactorily completed. If you are unable to provide the required information, we may need to suspend or decline your use of relevant platform features.

3.4. Enhanced checks apply where there is a higher risk of money laundering, including for transactions involving politically exposed persons (PEPs), high-risk countries identified by HM Treasury, or unusually large or complex transactions.

4. Sanctions Screening

4.1. We screen users involved in property transactions against the Office of Financial Sanctions Implementation (OFSI) consolidated sanctions list and other relevant sanctions lists maintained by UK and international authorities.

4.2. We will not proceed with any transaction where a confirmed sanctions match is identified. Sanctions matches are escalated immediately in accordance with our internal procedures.

5. Reporting Suspicious Activity

5.1. If you have concerns about suspected money laundering or financial crime connected to activity on the platform, please contact us at compliance@britestate.co.uk.

5.2. You can also report suspected financial crime directly to the National Crime Agency (NCA) via the NCA website, or to Action Fraud at actionfraud.police.uk.

5.3. Please be aware that it is a criminal offence under POCA to “tip off” a person that a Suspicious Activity Report has been or may be made. If you have concerns, contact us privately rather than alerting any third party.

6. Regulatory Oversight

6.1. Britestate Ltd is supervised by HMRC for the purposes of the Money Laundering Regulations 2017. HMRC AML supervision registration reference: [HMRC REFERENCE].

6.2. A member of our board of directors has been appointed as the officer responsible for AML compliance, with oversight of our Money Laundering Reporting Officer (MLRO).

6.3. We maintain records of all customer due diligence and transaction records for a minimum of five years in accordance with Regulation 40 of the MLR 2017.

6.4. For external concerns about money laundering activity on the platform, contact: compliance@britestate.co.uk