Anti-Money Laundering (AML) Policy

Scott Ford Management Limited

www.scottcastle.uk

Scott Ford Management Limited (“the Company”) is committed to complying with all UK Anti-Money Laundering (AML) legislation and regulations, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended.
 

As an HMRC-registered entity for AML supervision (Registration No. XHML00000204815), we recognise our legal and regulatory obligations to prevent money laundering, terrorist financing, and financial crime.
 

The Company is also:
- UKALA Registered and Audited (No. 73775)
- Client Money Protection (CMP) Registered, including Professional Indemnity Insurance
- Registered with the Property Redress Scheme (PRS)
 

Our directors and Money Laundering Reporting Officers (MLROs) are:
- Robert Scott (Director & MLRO)
- Katrina Ware (Director & Deputy MLRO)

This policy applies to all employees, contractors, and representatives of Scott Ford Management Limited and covers:
- Property lettings
- Property management services
- Client fund handling
- All customer, landlord, and tenant interactions

We maintain a risk-based approach to identifying, monitoring, and mitigating money laundering and terrorist financing risks. Key controls include:
 

- Client Due Diligence (CDD) & Know Your Customer (KYC): All clients, landlords, and tenants are subject to identity verification and AML checks through SmartSearch, our regulated electronic verification provider.
 

- Enhanced Due Diligence (EDD): Conducted where higher risks are identified, such as non-UK clients, politically exposed persons (PEPs), or transactions involving high-value cash.
 

- Internal Control Limit: The Company has a strict internal control limit of £1,000 per client. Where transactions exceed this threshold, we will request and verify proof of the origin of funds to ensure transparency and compliance.
 

- Ongoing Monitoring: All transactions are monitored through both internal accounting systems and external accounting software (Xero). We work with external accountants for independent oversight.
 

- Segregation of Client Money: All client funds are ring-fenced in separate client accounts for property lettings and property management, ensuring full transparency and compliance.
 

- Adherence to RICS Standards: We follow the RICS Code of Practice for Property Management and the RICS Client Money Handling Code, ensuring that all client funds are handled in line with industry best practice and independently auditable standards.

Scott Ford Management Limited uses SmartSearch, a leading AML compliance and electronic verification platform, to conduct all AML checks.
 

SmartSearch provides:
- Electronic identity verification using multiple data sources
- Document verification and biometric checks
- PEP and Sanctions screening with daily monitoring against global databases
- Ongoing monitoring to alert us to any changes in a client’s risk status
- Audit trails to evidence compliance with HMRC, RICS, and regulatory requirements
 

This ensures a robust, efficient, and fully compliant AML checking process for all clients.

We undertake CDD on all clients before entering into a business relationship. This includes:
- Verification of identity and address using SmartSearch
- Understanding the purpose and intended nature of the business relationship
- Recording beneficial ownership information where applicable
- Retaining records securely for a minimum of five years after the end of the business relationship

All staff are required to be vigilant in identifying and reporting suspicious activity.
 

Reporting Procedure:
- Suspicious activity must be reported to the MLRO (Robert Scott) or Deputy MLRO (Katrina Ware).
- The MLRO will assess the suspicion and, where appropriate, submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
 

Staff Protection:
No employee will suffer any detriment for reporting a suspicion in good faith.

We provide regular AML training to all staff to ensure awareness of:
- Money laundering risks in property management and lettings
- The Company’s AML policies and procedures
- How to identify and report suspicious activity
- Regulatory updates and obligations

We maintain comprehensive records of:
- CDD/EDD checks conducted through SmartSearch
- Client communications
- Transaction histories (via internal and Xero accounting software)
- Suspicious Activity Reports (where applicable)
 

All records are securely stored and made available to regulators upon request.

As a UKALA registered and audited firm, our AML framework is subject to independent audits, ensuring compliance and continuous improvement.
 

We also comply with RICS audit requirements for property management and client money handling, ensuring client funds are safeguarded and processes remain transparent.

This policy will be reviewed annually or earlier if there are changes in legislation, regulation, or business operations.
 

Approved by the Board of Directors
Scott Ford Management Limited
Review Date : April 2026