Legal
Anti-Money Laundering Policy
Last updated: [01/10/2026]
Nestello Estate Agents Limited is committed to preventing its business from being used for money laundering, terrorist financing or other forms of financial crime.
As an estate agency business, we are required to comply with applicable UK anti-money laundering legislation and regulations, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended.
We operate a risk-based approach to anti-money laundering compliance and maintain appropriate policies, controls and procedures to identify, assess and manage relevant risks.
1. Customer Due Diligence
We may be required to carry out Customer Due Diligence (CDD) before establishing or continuing a business relationship with a customer.
CDD may include verifying:
The identity of individuals.
The identity and legal status of companies and other organisations.
The identity of beneficial owners and persons exercising control.
The authority of individuals acting on behalf of another person or organisation.
Relevant information concerning the purpose and nature of the business relationship.
Depending on the circumstances and level of risk, we may request identification documents, proof of address, company information and other information necessary to complete our checks.
HMRC's current estate agency guidance confirms that both buyers and sellers can be customers for AML purposes and that estate agents should identify the relevant parties to a transaction.
2. Risk-Based Approach
We assess money laundering, terrorist financing and proliferation financing risks associated with our business and customers.
Our assessment takes account of factors including:
The nature of the customer.
The property and transaction involved.
The geographical areas involved.
The services being provided.
The value and nature of the transaction.
How we interact with the customer.
Whether there are unusual or unexplained circumstances.
Any relevant sanctions, adverse information or other risk indicators.
HMRC requires estate agency businesses to carry out and maintain an appropriate business risk assessment and to reflect identified risks in their policies, controls and procedures.
3. Enhanced Due Diligence
Where a customer or transaction presents a higher level of risk, we may carry out Enhanced Due Diligence (EDD) and additional monitoring.
Additional information may be requested where appropriate, including information relating to:
Source of funds.
Source of wealth.
The purpose of the transaction.
Ownership and control structures.
The customer's circumstances.
Connections to higher-risk jurisdictions.
Other factors identified through our risk assessment.
The level of checks we carry out will depend on the circumstances and assessed level of risk.
4. Politically Exposed Persons
Where applicable, we will take appropriate measures when dealing with a Politically Exposed Person (PEP), their family members or known close associates, in accordance with applicable legislation and guidance.
Additional checks and approval procedures may be required depending on the circumstances and level of risk.
5. Sanctions
We may conduct appropriate sanctions checks as part of our compliance procedures.
Where a customer, beneficial owner or other relevant party appears to be subject to financial sanctions, we will take appropriate action in accordance with applicable UK sanctions legislation and guidance.
We may delay, refuse or terminate a transaction or business relationship where required by law.
6. Source of Funds and Source of Wealth
Where appropriate, we may request information or evidence concerning the source of funds being used in connection with a property transaction.
In higher-risk circumstances, we may also request information regarding the source of wealth of the relevant customer.
Examples of information that may be requested include evidence relating to:
Savings.
Property sales.
Mortgages or other financing.
Inheritance.
Investments.
Business income.
Gifts or other sources of funds.
The information required will depend on the circumstances and our risk assessment.
7. Suspicious Activity
We take potential money laundering and financial crime seriously.
Where we identify concerns or reasonable grounds for suspicion, we will follow our internal procedures and consider whether a Suspicious Activity Report (SAR) should be submitted to the National Crime Agency (NCA).
Our staff must escalate relevant concerns to the appropriate Money Laundering Reporting Officer.
We will comply with applicable legal restrictions concerning the disclosure of information relating to suspicious activity reports.
8. Money Laundering Reporting Officer
Nestello Estate Agents has appointed responsible officers to oversee our anti-money laundering procedures.
Money Laundering Reporting Officer (MLRO):
Rajesh Joseph, Company Director
Deputy MLRO:
Bibin Benny
The MLRO is responsible for receiving and reviewing internal reports of suspected money laundering or other relevant financial crime concerns and determining what further action is required.
9. Staff Training
We provide appropriate anti-money laundering training to relevant members of staff.
Training may cover:
Customer Due Diligence.
Identifying suspicious activity.
Risk assessment.
Source of funds and wealth.
Sanctions and PEPs.
Internal reporting procedures.
Record keeping.
Relevant changes to legislation and regulatory guidance.
Training is provided at induction and refreshed as appropriate to ensure staff remain aware of their responsibilities.
10. Record Keeping
We maintain appropriate records relating to our AML procedures, including relevant customer due diligence and risk assessment information.
Records are retained for the period required by applicable legislation and regulatory requirements and are handled in accordance with our Privacy Policy and data protection obligations.
11. Third-Party Compliance Providers
Where appropriate, we may use third-party identity verification, compliance or technology providers to assist with customer due diligence or related checks.
The use of a third-party provider does not remove our responsibility to comply with our legal and regulatory obligations. HMRC's current guidance specifically notes that estate agency businesses remain responsible for ensuring that their AML obligations are met when third-party providers are used.
12. Refusing or Delaying a Transaction
We may be unable to proceed with a business relationship, property transaction or service where:
Required identity information cannot be obtained or verified.
Required due diligence cannot be satisfactorily completed.
The customer does not provide information reasonably required for our compliance checks.
We identify an unacceptable level of money laundering or financial crime risk.
We are legally required to refuse or delay the transaction.
We have concerns that require further investigation.
We will not disclose information where doing so would breach applicable law or could prejudice a suspicious activity investigation.
13. Our Commitment
Nestello Estate Agents is committed to maintaining effective controls to reduce the risk of our business being used for money laundering, terrorist financing or other financial crime.
Our AML policies and procedures are reviewed periodically and updated where necessary to reflect changes in legislation, regulatory guidance, our business activities and identified risks.
14. Contact Us
If you have questions about our Anti-Money Laundering Policy, you can contact us:
Nestello Estate Agents Limited
Regus, Office 101
1 Meridian South
Meridian Business Park
Leicester
LE19 1WY
United Kingdom
Telephone: 0116 495 0505
Email: sales@nestelloestateagents.co.uk
Company Number: 15774860
Last updated: 1 October 2026