Money Laundering Policy

At Noble Harbour we actively safeguard against becoming involved in the processing of illegal or improper gains for, or at the expense of, our clients.

It is our policy not to assist with such transactions, and we are duty bound under section 330 of the Proceeds of crime Act 2002 to disclose, in the course of practice, a suspicion that an act of money laundering is occurring. We are aware that failure to do so would be construed as an unlawful act and could place the firm and its representatives at risk of criminal and civil proceedings.

In view of the provisions of regulations 20 and 21 of the Money Laundering Regulations 2007, we have established and endeavour to maintain appropriate and risk sensitive policies in relation to the following:

• Customer due diligence measures; as defined within Part 2 of the Money laundering Regulations 2007
• On-going monitoring of such measures
• Reporting procedures
• Record keeping
• Internal control procedures
• Risk assessment and management
• The monitoring and managing of compliance with, and the internal communication of, such policies and procedures

We are committed to ensuring that all of our employees are:

• Aware of the law relating to money laundering and terrorist finance
• In receipt of training in the recognition of, and appropriate methods of dealing with, transactions and activities which may relate to money laundering or terrorism financing.
• Able to easily reference the firm's procedural provisions relating to money laundering requirements, as provided within the on-line, and hard copy format of the office manual.
• Confident in the knowledge that any issues raised with the MLRO will be sensitively and appropriately managed.
• It is the responsibility of Gareth Noble, the designated MLRO, to ensure appropriate communications with the SOCA; appropriate disclosure to clients when required; and the maintenance of records of all disclosures and reports.

To enable us to confirm the identity of our clients we require the following documentation to be provided, in person, by client upon instruction:

Proof of Identity:

• Current, signed, full national passport
• Current, full UK driving licence (both sections required)
• Current UK provisional photo card driving licence (both sections required)
• Services ID card
• National ID card
• Inland revenue PAYE coding notice
• Benefits book or Benefits Agency/department of Works and Pensions notification letter
• Copy of Company Certificate of Incorporation

Proof of address:

• Bank or Building Society statement
• Recent utility bill
• Current local authority tax bill
• Most recent, original mortgage statement
• Local council rent card or local council tenancy agreement

In the event of the client being genuinely unable to attend in person to supply the appropriate documentation, it is the policy of the firm to accept officially authenticated copy documentation from fellow professionals only, in the first instance.

Additionally, Noble Harbour utilizes the services of MDA SearchFlow Ltd as a form of online ID verification.

In situations where the firm is instructed by both a prospective purchaser and the mortgage lender, the provisions of the Council of Mortgage Lenders Handbook are strictly observed at all time; as well as having close regard to the provisions of Rule 3 (Conflict of interests) and Rule 4 (Confidentiality and disclosure) of the Solicitor's Code of Conduct 2007.