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What is today's blog about?
In this week’s blog, we take a look at the March 2022 RICS anti-money laundering sanctions update. You can read the full update here.
This is essential reading for all RICS APC and AssocRICS candidates, as well as qualified AssocRICS and Chartered Surveyors.
Why has an update been issued?
The RICS have issued an anti-money laundering update following the Russian invasion of Ukraine and financial sanctions imposed by the UK Government as a result.
The Sanctions and Anti-Money Laundering Act 2018 is the key legislation relating to the RICS update. This established the UK Sanctions List, which confirms who is subject to sanctions.
What is our responsibility in relation to money laundering as surveyors?
RICS professionals deal with a wide variety of clients and have a key role in identifying and managing the risk of money laundering.
The RICS Rules of Conduct specifically state that RICS members and firms must not facilitate money laundering or financial crime. In doing so, firms must have robust processes in place and members must follow these diligently. These processes must identify any politically exposed persons (PEPs), persons with significant control (PSCs) and any imposed sanctions.
Comprehensive guidance is already set out by RICS in the Professional Statement Countering Bribery and Corruption, Money Laundering and Terrorist Financing. To review a summary of the guidance, head to our blog article.
How can surveyors undertake sufficient money laundering due diligence?
Surveyors must undertake anti-money laundering due diligence as part of their pre-instruction checks, as well as regularly checking the status of higher risk clients. This will include reviewing a current copy of the Sanctions List. Firms who are at higher risk may use specialist software to ensure that comprehensive due diligence is undertaken.
If a red flag or a money laundering concern is identified by a relevant firm, e.g., a breach of financial sanctions or that frozen assets are held, then a report must be submitted to the Office for Financial Sanctions (OFSI).
How can we help?
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Stay tuned for our next blog post to help build a better you.
N.b. Nothing in this article constitutes legal, professional or financial advice.