Statement of Anti-Money Laundering Policy
Carigiet Cowen is committed to being fully compliant with the provisions of the Money Laundering, Terrorist Financing & Transfer of Funds (Information on the Payer) Regulations 2017, and the National Risk Assessment of Money Laundering (ML) and Terrorist Financing (TF) Guidance 2025.
Carigiet Cowen is committed to following all RICS Professional Standards. We have ensured that all staff are familiar with the contents of the specific Professional Standard entitled “Countering financial crime: bribery, corruption, money laundering, terrorist financing, and sanctions violations Global 2nd Edition, September 2025 effective from 17 December 2025.
As a Firm of RICS regulated Chartered Surveyors, we are involved with the sale of commercial properties; Carigiet Cowen does not transact on residential properties. We are also involved with the leasing of commercial properties including those which may attract a rent to the value of 10,000 Euros or equivalent per month.
The purchase of property and the letting of property with large rental value attached has the potential to be used by criminals to launder the proceeds of criminal activity. It is recognised that professionals working in the property sector such as ourselves need to be fully aware of the presence of such activity in the market, and that we need to have clear policies and procedures in place to identify and report any suspicions of money laundering.
Identity Checks, Client Due Diligence and Monitoring
We conduct due diligence enquiries on all relevant parties wishing to buy or sell an interest in land or property to verify their identity and the identity of any beneficial owners. We have systems and controls in place to carry out ID verification checks for all legal owners for whom we are acting in any agency sales or lettings capacity. We also have similar systems and controls in place for any prospective purchaser or tenant of property with which we are dealing.
We undertake ongoing monitoring of all ID verification documentation. All relevant information concerning ID checks is held securely in line with Carigiet Cowen’s GDPR policy.
Proof of the Source of Funds
We will require proof of the source of funds relating to the purchase of any land or property on which we are instructed to act.
The Nominated Officer
The Carigiet Cowen Nominated Officer for Anti Money Laundering Supervision (AMLS) is Iain Henderson. Any suspicious activity should be reported to the Nominated Officer.
Risk Assessment
Given the nature, location and scale of our estate agency business as it relates to the sale or leasing of land or property, the risks of money laundering activity taking place is considered to be low. All staff have been briefed and have read this policy document and are aware of the need to remain vigilant to identify any potential risks.
Referral to the National Crime Agency
Any suspicion or knowledge regarding money laundering or terrorist financing activity should be reported to the National Crime Agency, reported through the Nominated Officer.
Compliance with Financial Sanctions Regulations
Carigiet Cowen carries out Sanctions Checks on all clients for whom we are acting in any agency sales or letting capacity. We also carry out sanctions checks on any prospective purchaser or tenant of property with which we are dealing. These checks are carried out through the Government’s Sanctions List on-line portal. Carigiet Cowen recognises that if a match is found or suspected, then we have a responsibility to report such suspicions to the Office for Financial Sanctions Implementation (OFSI). It is recognised that with effect from 14 May 2025, Letting Agents are now subject to reporting obligations, with Letting Agents having been added to the list of “relevant firms” under financial sanctions regulations.
Certification
Carigiet Cowen is registered for anti-money laundering supervision with HMRC to carry out estate agency work under AMLS Registration No XDML00000187012. The registered premises is Suite 2 Telford House, Riverside, Warwick Road, Carlisle CA1 2BT.