1. Introduction

This Anti-Money Laundering (AML) Policy sets out the measures adopted by RP Capital Advisors Ltd to prevent, detect, and report illicit financial activities. The policy applies to all staff and contractors involved in leasehold disposals, acquisitions, and investment purchase and sales on behalf of clients. It is designed to ensure compliance with UK legislation, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and guidance from HM Revenue & Customs and the National Crime Agency.

2. Risk Assessment

We conduct regular risk assessments to identify, evaluate, and mitigate risks associated with money laundering and terrorist financing. Our methodology considers transaction value, client profile, property location, and source of funds. Risk factors are documented and reviewed annually, or sooner if circumstances change. The board is responsible for approving all risk assessment outcomes and ensuring appropriate controls are in place.

3. Customer Due Diligence (KYC)

All clients must undergo Customer Due Diligence (CDD) prior to any transaction. KYC procedures are performed by KYC4U, our appointed service provider. Individuals are required to provide valid photo identification and proof of address. Businesses must supply company registration documents, details of directors and beneficial owners, and evidence of trading activity. Enhanced due diligence will be applied for high-risk clients or transactions. All documentation is securely retained in accordance with data protection requirements.

4. Appointment of Money Laundering Reporting Officer (MLRO)

The board appoints Julie Perks as the Money Laundering Reporting Officer (MLRO), responsible for overseeing AML compliance. Julie Perks acts as the main point of contact for staff, regulators, and law enforcement agencies. Responsibilities include reviewing suspicious activity reports, maintaining AML records, and submitting reports to relevant authorities. The MLRO reports directly to the board and has authority to escalate concerns as necessary.

5. Ongoing Monitoring

We monitor all transactions and client relationships for unusual or suspicious activity. This includes periodic review of client profiles, scrutiny of source and movement of

funds, and assessment of transaction patterns. Any anomalies are investigated and, if warranted, reported to the MLRO for further action.

6. Staff Training

All staff receive AML training at induction and annually thereafter. Training covers regulatory requirements, recognising suspicious activity, and internal reporting procedures. Attendance is recorded and training materials are regularly updated to reflect changes in legislation and best practice.

7. Reporting Procedures

Staff must report any knowledge or suspicion of money laundering to the MLRO immediately. The MLRO is responsible for assessing reports and, where necessary, making formal disclosures to external authorities such as the National Crime Agency. Internal escalation procedures ensure confidentiality and protection for reporting staff.

8. Policy Review

This policy is reviewed at least annually by the board, or more frequently if regulatory changes or business developments require. Updates are communicated to all staff, and board approval is documented in meeting minutes.

By adhering to this AML Policy, RP Capital Advisors Ltd demonstrates its commitment to preventing financial crime and maintaining the integrity of its business operations.

This statement has been approved by the Board of Directors of RP Capital Advisors Ltd and will be reviewed annually.

Julie Perks, Principal
RP Capital Advisors Ltd

Simon Robinson, Principal
RP Capital Advisors Ltd