Product range

1. Estate Agent AML Document Review

Legal Eye will assess the compliance of your firm’s policies against HMRC, and will identify any action you need to consider in conjunction with the following:  

• Governance Risk based approach
• Customer due diligence
• Source of funds and source of wealth (where appropriate)
• Suspicious activity reporting

The documents we will need to review which are relevant to and include:  

Included as part of the AML Document Review is a comprehensive written action plan confirming the suggested corrective action required.

2. Estate Agent AML Independent Audit

Legal Eye will examine, evaluate and make recommendations regarding the adequacy and effectiveness of the firm’s anti-money laundering and counter-terrorist financing (CTF) policies, controls, and procedures (PCPs).

The audit will be used as a monitoring tool to track the firm’s compliance with the recommendations made.

The audit will consist of:

• Access to information—including your AML and CTF risk assessment, policies, training records, etc
• Access to relevant staff
• Testing the effectiveness of existing procedures and controls
• Testing of any automated systems in use by the firm
• Record-keeping
• Training

The conclusion of the audit will contain an evaluation of the findings of the audit, together with recommendations for development of the firm’s policies, controls and procedures.  

It will identify whether the firm’s policies, controls and procedures are: 

• adequate in the light of the firm’s risk assessment working as they need and are intended to do
• It also sets out any areas of non-compliance, both with the HMRC and with the firm’s policies, identified during the audit.

The recommendations will cover areas for improvement or change as well as specific actions to rectify problems or non-compliance.

If required, we can then provide you with a quotation to conduct the work to resolve the corrective actions. This additional work can be tailored to your specific needs and budget and would include a resolution report confirming that the corrective actions have been completed. 

3. Estate Agent AML Independent Audit including Certification

This is a rolling contract to include an AML Independent Audit every other year and a Re-Certification audit for the alternate years. 

Legal Eye will examine, evaluate, and make recommendations regarding the adequacy and effectiveness of the firm’s anti-money laundering and counter-terrorist financing (CTF) policies, controls, and procedures (PCPs).

The audit will be used as a monitoring tool to track the firm’s compliance with the recommendations made.

The audit (required biennially) will be used as a monitoring tool to track the firm’s compliance with the recommendations made. The audit will consist of:

• Access to information—including your AML and CTF risk assessment, policies, training records, etc
• Access to relevant staff
• Testing the effectiveness of existing procedures and controls
• Testing of any automated systems in use by the firm
• Record-keeping
• Training
• Random selection of files for review focused on the AML aspect of the file (up to a maximum of 10 files)

The conclusion of the audit will contain an evaluation of the findings of the audit, together with recommendations for development of the firm’s policies, controls and procedures.

It will identify whether the Firm’s policies, controls and procedures are:       

• adequate in the light of the Firm’s risk assessment
• working as they need and are intended to do

It also sets out any areas of non-compliance, both with the HMRC and with the firm’s policies, identified during the audit. The recommendations will cover areas for improvement or change as well as specific actions to rectify problems or non-compliance.

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4. Estate Agent AML Independent Audit Re-Certification (Remote access)

Following the AML Audit in year 1, Legal Eye will carry out a re-certification for year 2 and biennially thereafter.

Legal Eye will need to review the following policies which are relevant to and include:  

• AML policies
• Due Diligence policies
• Risk Management policies
• Supporting policies & documents (ie; Anti-Bribery & Corruption Policy)
• Training & Development records

Legal Eye will also carry out the following:       

• 2 Staff interviews
• 2 file reviews
• A maximum 1-hour telecom/video call with MLRO/MLCO

Should further minor correctives be required, the firm will have 28 days to complete. 

Once completed and independently confirmed by Legal Eye, an AML Audit Certificate will be issued.

Re-Certification criteria:

The AML Audit Certificate is awarded for a period of 1 year subject to the firm meeting the following criteria:

• No significant changes to the AML regulations which the firm haven’t adopted
• The firm has not merged or acquired another practice
• There have been no significant changes to the firm’s scope of services provided
• No significant findings have been found from the firm’s file reviews of any AML compliance failures
• AML training must be up to date for all relevant staff
• The firm’s AML Firmwide Risk Assessment Policy must be up to date
• No material correctives highlighted during the review

Failure to comply with the above requirements will invalidate your certificate and a further full AML Independent Audit will be required.

Please note that an AML Independent Audit will be required every 2 years.