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

Last updated: [01/10/2026]

Nestello Estate Agents Limited (“Nestello Estate Agents”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store and protect your personal information when you visit our website, contact us, request a property valuation, enquire about a property, instruct us to sell or buy a property, or otherwise use our services.

Nestello Estate Agents Limited is registered in England and Wales under company number 15774860.

Registered Office:
Regus, Office 101, 1 Meridian South, Meridian Business Park, Leicester, LE19 1WY, United Kingdom

Email: sales@nestelloestateagents.co.uk
Telephone: 0116 495 0505

How do we collect your information?

We may collect personal information:

  • Directly from you when you contact us by telephone, email, website forms or in person.

  • When you request a property valuation.

  • When you enquire about a property.

  • When you register as a buyer.

  • When you instruct us to sell or otherwise assist with a property transaction.

  • When you communicate with us through social media or other communication platforms.

  • From third parties where this is lawful and necessary for the services we provide.

  • Automatically when you use our website through cookies and similar technologies.


4. How do we use your personal information?

We may use your information to:

  • Respond to enquiries and requests.

  • Arrange and provide property valuations.

  • Market properties on behalf of clients.

  • Provide property information to prospective buyers.

  • Assist with property purchases and sales.

  • Communicate with you regarding a property transaction.

  • Carry out identity and anti-money-laundering checks where required.

  • Provide information to relevant professional advisers and service providers involved in a transaction.

  • Process payments and maintain appropriate business records.

  • Improve our website, services and customer experience.

  • Send marketing communications where we have a lawful basis to do so.

  • Comply with legal, regulatory and professional obligations.

  • Prevent fraud and protect our business, clients and customers.

  • Establish, exercise or defend legal claims where necessary.


5. Our lawful basis for processing your information

We will only process your personal data where we have a lawful basis to do so.

Depending on the circumstances, this may include:

Consent

Where you have given us permission to use your information for a specific purpose.

Contract

Where processing is necessary to provide a service to you or to take steps at your request before entering into a contract.

Legal obligation

Where we are required to process your information to comply with a legal or regulatory requirement.

Legitimate interests

Where processing is necessary for our legitimate business interests, provided that those interests do not override your rights and interests.

Vital interests

In limited circumstances, where processing is necessary to protect someone's vital interests.


6. Property marketing and buyer enquiries

If you are selling a property through Nestello Estate Agents, we may use information about your property to market it through property portals, our website, social media, advertising and other marketing channels.

If you enquire about a property, we may use the information you provide to assess your requirements, respond to your enquiry and arrange viewings or further communication.

Where necessary, relevant information may be shared with the property owner, buyer, seller or professional parties involved in the transaction.


7. Anti-money laundering and identity checks

Estate agents are subject to legal and regulatory requirements relating to money laundering and identity verification.

Where required, we may collect and process identification and other information to carry out appropriate checks.

We may use third-party providers to assist us with these checks where appropriate and lawful.


8. Who may receive your information?

Depending on the circumstances, we may share relevant personal information with trusted third parties where this is necessary to provide our services or comply with legal obligations.

These may include:

  • Solicitors and conveyancers.

  • Mortgage and financial advisers.

  • Property portals.

  • Identity and anti-money-laundering verification providers.

  • Professional advisers.

  • Technology, website and IT service providers.

  • Payment providers.

  • Government bodies, regulators and law-enforcement authorities where legally required.

  • Other parties directly involved in a property transaction where sharing the information is necessary and lawful.

We do not sell your personal data.


9. Cookies and website analytics

Our website may use cookies and similar technologies to help the website function, understand how visitors use the website and improve our services.

Cookies may be used for purposes such as:

  • Essential website functionality.

  • Website security.

  • Remembering preferences.

  • Understanding website traffic and usage.

  • Measuring marketing and advertising performance.

Where required by law, we will request your consent before placing non-essential cookies on your device.

You can manage or disable cookies through your browser settings and, where available, our cookie consent tools.

For more information, please see our Cookies Policy.


10. Marketing communications

Where we have a lawful basis to do so, we may contact you with information about properties, services, market updates, valuations and other information that may be relevant to you.

You can opt out of marketing communications at any time by contacting:

sales@nestelloestateagents.co.uk

If you receive marketing emails from us, you may also use the unsubscribe option included in the email.


11. How long do we keep your information?

We will only keep your personal information for as long as reasonably necessary for the purpose for which it was collected.

The length of time we keep information may depend on:

  • The nature of our relationship with you.

  • Legal and regulatory requirements.

  • Our contractual obligations.

  • Accounting and record-keeping requirements.

  • The need to establish, exercise or defend legal claims.

When personal information is no longer required, we will take reasonable steps to securely delete or anonymise it.


12. Your data protection rights

Under UK data protection law, you may have the right to:

  • Request access to the personal information we hold about you.

  • Ask us to correct inaccurate or incomplete information.

  • Ask us to delete your personal information in certain circumstances.

  • Ask us to restrict how we process your information in certain circumstances.

  • Object to certain types of processing, including direct marketing.

  • Request the transfer of certain information to another organisation.

  • Withdraw consent where we rely on consent to process your information.

These rights are subject to certain legal exceptions and limitations.

To exercise your rights, contact:

sales@nestelloestateagents.co.uk

We may need to verify your identity before processing certain requests.


13. Automated decision-making

Nestello Estate Agents does not make decisions about you based solely on automated processing that produce legal or similarly significant effects.


14. International transfers

Some of our technology and service providers may process information outside the United Kingdom.

Where personal data is transferred outside the UK, we will take appropriate steps to ensure that the transfer is lawful and that appropriate safeguards are in place where required.


15. Data security

We take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

However, no method of transmitting or storing information online can be guaranteed to be completely secure.


16. Third-party websites

Our website may contain links to third-party websites, including property portals, professional organisations and other external services.

We are not responsible for the privacy practices or content of third-party websites.

We recommend reviewing the privacy policy of any third-party website you visit.


17. Your right to complain

If you have a concern about how we have handled your personal data, please contact us first so that we can investigate and try to resolve the matter.

Email: sales@nestelloestateagents.co.uk

You also have the right to complain to the UK's data protection supervisory authority:

Information Commissioner's Office (ICO)

You can find information about making a complaint through the ICO's official website.


18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our services, legal requirements or the way we process personal information.

Any updated version will be published on this page, together with the date it was last updated.


19. Contact us

If you have any questions about this Privacy Policy or how Nestello Estate Agents handles your personal information, please 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