Kelly.ie have the following Anti-Money Laundering procedures in place – as per the Anti-Money Laundering & Terrorist Financing Act 2010. These regulations apply to and are observed by both JB Kelly Estate Agents and Noel Kelly Auctioneers.
Customer Due Diligence (CDD)
As a provider of property services, Customer Due Diligence is compulsory. The following documents are required for each transaction, where the client is a:
- Photo ID (Passport, Full Drivers License, National Identity Card, Social Welfare Card with photo, National Age card
- Non photo verification (Revenue Commissioners letter with PPSN, Dept of Social Protection letter with PPSN, Utility Bill, medical Card)
- Corporate Clients – this also covers Receivers
- Memorandum and Articles of Association
- List of Directors names
- Verify identity of one director and one signatory (as for Individual)
- Beneficial Owners identity can be verified via clients solicitor
- Copy of Trust Deed
- Full name of Trust
- Nature and purpose of establishment
- names of all Trustees and name and address of any protector/settler
- Verify the identity of one Trustee and one signatory as for Individual
- Obtain a copy of Partnership Agreement
- Verify the identity of one Partner and one signatory as for Individual
Where a client refuses or cannot comply with the requirements of the Customer Due Diligence, we are legally obligated to cease provision of the property service.
- Records are maintained on file, regarding CDD of all clients for each transaction for a period of 5 years.
- Suspicions relating to ownership of property must be confirmed with the Property Registration Authority
- As per good practice, CDD for purchaser/lessee may also be undertaken.
Suspicious Transaction Reports (STR’s)
- The threshold for the amount of cash which can be accepted, without making a Suspicious Transaction Report (STR) is zero.
- Any cash received, unless where the PSP is absolutely satisfied as to its bona fides, or where the PSP has cause for concern relating to the client or purchaser, must be considered as suspicious and a Suspicious Transaction Report (STR) completed and forwarded to the Gardai nd Revenue.
AML training is undertaken annually as part of PSRA CPD programme.