Anti Money Laundering Policy

Rossiter Property Ltd is committed to conducting its business with the highest ethical standards, ensuring full compliance with all applicable laws and regulations aimed at combating money laundering and terrorist financing.

This policy has been developed to mitigate the risks associated with money laundering and terrorist financing in relation to the company’s operations and the sale of its products and services.

The policy outlines the individual responsibilities of employees and ensures that any third parties engaged to act on behalf of Rossiter Property Ltd adhere to these standards as well.

Rossiter Property Ltd is dedicated to ensuring full compliance with relevant laws. Any employee found in violation of this policy, or who permits others to do so, may face disciplinary actions, including dismissal, and could be subject to civil or criminal penalties.

Policy Statement on Anti-Money Laundering

Rossiter Property Ltd strictly complies with all applicable Anti-Money Laundering (AML) laws in its operations.

The company conducts business only with customers engaged in legitimate activities and whose funds are derived from lawful sources.

This policy aims to guide employees, contractors, and any third parties acting on behalf of Rossiter Property Ltd to identify and prevent breaches of AML laws, ensuring that they make decisions aligned with this corporate commitment.

Who is Subject to this Policy?

This policy applies to all operations of Rossiter Property Ltd.

What’s the Risk?

Violations of AML laws can result in severe civil and criminal penalties for both companies and individuals, including significant fines, imprisonment, extradition, blacklisting, revocation of licenses, and disqualification of directors.

Furthermore, violations can have damaging practical consequences such as reputational harm, loss of business relationships, and the imposition of operational restrictions.

What is Money Laundering and Terrorist Financing?

Money laundering involves the exchange of money or assets obtained through criminal activities for money or assets that appear legitimate. It also includes any funds used to support terrorism, regardless of their source.

The following activities are considered money laundering and are prohibited under this policy:

• Conversion or transfer of property with the knowledge or suspicion that it originates from criminal activity, with the intent to conceal its illicit origin.
• Conducting financial transactions involving criminal property.
• Concealing or disguising the true nature, source, location, or ownership of criminal property.
• Acquiring, possessing, or using criminal property.
• Promoting unlawful activity or assisting someone involved in unlawful activity.
• Participating in or facilitating any of the above actions.
• Under this broad definition, any Rossiter Property Ltd employee who becomes aware of or suspects criminal property within the business, and continues to engage with it without reporting their concerns, may be violating the law.

Property can be considered criminal property even if the underlying criminal activity occurred abroad.

Terrorist financing may involve an attempt to hide the origin or use of funds intended for criminal purposes.

Red Flags

Suspicious activities that may indicate money laundering or terrorist financing and should be reported include:

• A customer providing incomplete, false, or suspicious information, or being reluctant to provide full details.
• Payment methods or volumes that deviate from typical business practices, such as cash payments, payments from unrelated third parties, or use of multiple financial instruments.
• Orders or purchases inconsistent with the customer's normal business.
• Payments to or from unrelated parties, countries with high risks of money laundering, or tax havens.
• Structuring transactions to avoid reporting or record-keeping requirements.
• Unusual wire transfer patterns or spikes in customer activity.
• Complex business structures or payment schemes with no clear purpose.

This list is not exhaustive. Any deviation from standard practice should prompt further investigation according to this policy.

Compliance Controls

Rossiter Property Ltd is responsible for fostering a culture of compliance and ensuring effective controls are in place to prevent, detect, and respond to money laundering and terrorist financing. The company also emphasizes the serious consequences of non-compliance to all employees.

Employee Responsibility

Employees must familiarize themselves with and adhere to this policy, recognizing and escalating any potential red flags related to AML. All concerns must be reported to the Director of Rossiter Property Ltd, Andrew Pearce, without informing those involved in the transaction or taking any actions before receiving guidance.

Due Diligence and Record Keeping

Rossiter Property Ltd is committed to conducting due diligence at the beginning of any business relationship, as well as when red flags arise, on suppliers, agents, counterparties, and anyone with whom the company has financial dealings. This ensures compliance with legal standards and helps prevent illegal activities.

Suspicious activities must be reported to the Director, Andrew Pearce.

Maintaining records is essential to provide an audit trail for any investigations.

Non-Compliance

Employees who violate this policy may face disciplinary actions, in addition to any legal penalties arising from their actions.

Updates, Review, and Ownership

This policy will be periodically reviewed and updated as necessary. The most current version will be made available on the Rossiter Property Ltd website.