1. Purpose
This Anti-Money Laundering (AML) Policy outlines the procedures and controls that Premier Portfolio Services Ltd, trading as Premier Sourced, has implemented to prevent the business from being used to facilitate money laundering or terrorist financing. It ensures compliance with:
The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017)
The Proceeds of Crime Act 2002
Guidance issued by HMRC and The Joint Money Laundering Steering Group (JMLSG)
2. Business Overview
Premier Portfolio Services Ltd, trading as Premier Sourced, operates a property deal sourcing platform. The company facilitates two types of property transactions:
Criteria 1: Properties sourced and acquired directly by Premier Property (a related entity) that meet strict financial criteria (e.g. infinite ROCE within 3 years).
Criteria 2: Properties meeting a 17-point checklist, made available to third-party investors through the platform.
Although no client funds are held, the business engages in property introductions, facilitated negotiations, and transaction coordination, all of which are regulated activities under HMRC’s supervision.
3. Key AML Risks
The following risks have been identified and are regularly reviewed:
Use of property transactions to launder criminal proceeds
Third-party or opaque corporate structures with unclear ownership
Offshore investors or parties from high-risk jurisdictions
Franchisees operating independently and inconsistently
Payment of sourcing fees by unrelated third parties
Use of unregistered titles, cash payments, or shell companies
4. Customer Due Diligence (CDD)
Premier Sourced conducts Customer Due Diligence (CDD) on:
All property investors purchasing deals via the platform (Criteria 2)
All franchisees and deal sourcers using the platform
Vendors in off-market transactions where Premier Sourced facilitates direct-to-vendor introductions
CDD Requirements:
Premier Sourced conducts Customer Due Diligence (CDD) on:
Proof of identity (valid passport or UK photo ID)
Proof of address (utility bill or bank statement within last 3 months)
Source of Funds (bank statements, loan offers, etc.)
Source of Wealth where appropriate
Sanctions & PEP (Politically Exposed Person) checks via digital screening
Enhanced Due Diligence (EDD) is triggered for:
Investors from FATF high-risk countries
Complex company structures or trusts
Franchisees with inconsistent behaviour or incomplete compliance
Deals involving unusual payment methods or rapid turnarounds
5. Franchisee & Sourcer AML Obligations
All Premier Sourced franchisees must:
Undergo onboarding checks and training
Submit vendor ID, comparables, SOF, and valuation for every deal
Use the platform's internal system for deal uploads and updates
Comply with all audit requests and spot checks
Failure to comply will result in suspension or removal from the platform.
6. Monitoring & Reporting
Ongoing Monitoring
All deal submissions are reviewed before platform approval
Alerts raised for sudden buyer substitutions, unusually high fees, or inconsistent documentation
Random quarterly audits of 10% of sourcer submissions
Investor tracking to ensure payment source matches CDD documents
Internal Suspicion Reporting
All staff and platform moderators are trained to recognise red flags. Any suspicion must be reported to the Nominated Officer (NO) immediately.
External Reporting
Where suspicion is confirmed, a Suspicious Activity Report (SAR) is submitted to the National Crime Agency (NCA).
7. Record Keeping
Premier Sourced retains the following records for 5 years:
ID, proof of address, and SOF documents
Deal audit trails, comparables, and valuation reports
Communication logs and decision-making notes
SAR submissions and investigation outcomes
All records are stored digitally on encrypted, access-controlled systems.
8. AML Governance & Roles
Role
Nominated Officer (NO)
MLRO (if applicable)
Franchise Director
Admin Team
Name or Position
[Insert Name – e.g. Compliance Manager]
[Insert Name]
[Insert Name]
[Insert Name]
Responsibility
Receives SARs and liaises with the NCA
Overall responsibility for AML compliance
Ensures franchisees uphold AML standards
Performs ID, SOF checks, and audit support
9. Training
All employees, contractors, and franchisees are required to complete annual AML training covering:
Recognising red flags
CDD and EDD procedures
SAR submission process
Recent changes to AML legislation
Training completion is logged and reviewed by the Nominated Officer.
10. Policy Review
This AML policy will be reviewed:
At least annually
After any major change in business model
Following any regulatory updates or audit feedback
Training completion is logged and reviewed by the Nominated Officer.
Approved by:
[Insert Name]
Director – Premier Portfolio Services Ltd t/a Premier Sourced
Date: [Insert Date]
