Anti-money-laundering and know-your-counterparty.

Framework

Luxury Hotel Brokers operates a written AML and KYC framework proportionate to its engagements. The framework aligns with the standards of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, and with published Financial Action Task Force guidance applicable to high-value non-financial businesses.

Counterparty due diligence

Prior to engagement, the institution identifies its principal, verifies identity from reliable independent sources, establishes beneficial ownership and control, and forms a view on the purpose and nature of the intended transaction or engagement. Enhanced measures apply to politically exposed persons, higher-risk jurisdictions and complex ownership structures.

Source of funds

For engagements involving acquisition or disposal, the institution establishes the source of funds and, where appropriate, source of wealth to a standard commensurate with the size and complexity of the transaction.

Sanctions

Counterparties are screened against applicable UK, EU, US and UN sanctions lists on engagement and on a continuing basis for the duration of the engagement.

Suspicious activity

The institution maintains internal reporting procedures for suspicious activity, with a nominated officer responsible for evaluation and, where appropriate, disclosure to the United Kingdom Financial Intelligence Unit at the National Crime Agency.

Records

Records of counterparty due diligence, transactional information and internal reports are retained for the periods required by the applicable regulations.

Training

Personnel with material engagement responsibilities receive AML training on appointment and on a continuing basis. Training is refreshed on any material change to law, regulation or the institution's risk profile.

Contact

Enquiries regarding this statement may be directed to compliance@luxuryhotelbrokers.com.