Prime Letting & Management Ltd has completed a full business risk assessment in respect of the money laundering and/or terrorist financing risks posed to the business. This assessment identifies and evaluates the relevant risk factors and the associated control measure(s) in place. The risk assessment will be reviewed and updated by senior management as risks emerge/develop, or otherwise every two years (at a minimum).
Prime Letting and Management carries out an individual risk assessment on all clients. Based on the Irish National Risk Assessment for Money Laundering/Terrorist Financing, alomg with thebusiness risk assessment completed by Prime Letting and Management Ltd it is expected that the majority of clients of the business will be relatively low risk in this regard. The following conditions would influence the business to increase the clients’ risk rating from low to medium or high;
- The client is a large company, trust or legal entity with a complex system of beneficiaries
- The client is located abroad
- It is unlikely that any business engagement with the client will be conducted on a face to face basis
- The property service requested by the client is on a large scale e.g. sale of a large multi-unit development as opposed to a single residential home
- The final sale/ purchase of the property will not involve any other regulated professional (e.g. there will be no solicitor involvement)
- The client is a Politically Exposed Person (as defined in section 4 of this document)
- Any other factor which could increase the risk of the business being exposed to Money Laundering/Terrorist Financing.
Where up to four of any of there conditions apply, the risk rating will be increased to medium. Where more than 5 of any of these condition apply, the risk will be increased to high.
Where the client is a resident in any of the European Commission list of high risk third countries, they will automatically be treated as ‘High’ risk. Notwithstanding the conditions ratins set out above, where the business has any other reason to consider the client as ‘High’ risk, they will be identified and treated as such.
Where a client has been identified as ‘high’ risk, the business relationship will be monitored on an ongoing basis.
Due to the reglated nature of trading livestock, all clients and customers involved in transactions of this nature are consider low-medium risk. Prime LM Ltd follows the appropriate guidance from the Property Services Regulatory Authority when providing such services.
2. Carrying out Customer Due Diligence: