Our Anti-Money Laundering Policy

Purpose
This policy outlines the AML procedures Select Homes follows in its deal packaging activities to ensure compliance with UK anti-money laundering regulations. It focuses on verifying investor proof of funds, maintaining a thorough audit trail, managing overseas clients, and identifying and handling high-risk investors.

1. Investor Proof of Funds

1.1. Prior to any transactions, Select Homes requires investors to provide verified proof confirming that investment funds are from legitimate sources.
1.2. Acceptable documentation includes recent bank statements, financial reports, or other credible financial records.
1.3. Our team checks the authenticity of submitted documents by cross-referencing them with financial institutions or trusted third-party verification services.
1.4. All documents are stored securely and form part of our internal recordkeeping and audit trail.

2. Transaction Audit Trail

2.1. We maintain a detailed audit trail for every transaction, capturing all key documentation and data in a secure and accessible format.
2.2. This includes investor identity, funding proof, deal records, and any associated paperwork.
2.3. All correspondence—such as emails, written notes, and messages—is logged and archived.
2.4. Internal audits are routinely conducted to verify that our records are accurate and compliant.

3. Overseas Investor Due Diligence

3.1. For investors based outside the UK, we apply additional due diligence procedures to reduce risk linked to international transactions.
3.2. We independently verify the investor’s identity using reliable, secure sources.
3.3. The investor’s country of origin is reviewed, including its AML compliance standards and status on international risk watchlists.
3.4. We ensure all activities comply with both UK and relevant local laws concerning foreign investment and AML obligations.

4. Monitoring High-Risk Investors

4.1. Select Homes uses a risk-based approach to flag investors who may present a heightened risk of money laundering.
4.2. Factors that may classify an investor as high-risk include:
    a) Politically Exposed Persons (PEPs) or close associates of PEPs
    b) Residency in or ties to countries with weak AML oversight or corruption
    c) Prior involvement in suspicious financial conduct
    d) Transactions or behaviour patterns that appear unusual or unjustified
4.3. If deemed high-risk, the investor is subject to enhanced due diligence.
4.4. This includes deeper background checks, additional documentation, external reports, and senior management review before any engagement.
4.5. Ongoing monitoring is carried out throughout the relationship, with attention to any changes in status or behaviour.

Note
This policy provides a foundational framework. Select Homes advises consulting AML compliance professionals or legal counsel to ensure the policy remains up to date with evolving regulatory requirements.