Anti-Money Laundering (AML) Policy

Effective Date: 1^st September 2025

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Swift Sale Properties Ltd (“the Company”) is committed to conducting its business in full compliance with the UK Money Laundering Regulations 2017 (as amended), the Proceeds of Crime Act 2002, and the Terrorism Act 2000. This policy sets out our approach to preventing money laundering, terrorist financing, and other financial crime.

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1. Scope and Commitment

This policy applies to:

• All staff, directors, and contractors of Swift Sale Properties Ltd
• All investors and other parties engaging in business with the Company
• We are committed to maintaining high standards of integrity and accountability to prevent our business being used for money laundering or terrorist financing.

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2. Customer Due Diligence (CDD)

We conduct identity and verification checks on all property investors (private loan relationships), and relevant third parties before establishing a business relationship or completing a transaction.

This includes:

• Proof of identity (valid government-issued photo ID)
• Proof of address (dated within the last 3 months)
• Source of funds checks for investors to verify that investment funds are legitimate

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3. Risk-Based Approach to Customer Due Diligence

At Swift Sale Properties Ltd, we adopt a risk-based approach to customer due diligence (CDD). This means that the level of checks we carry out depends on the level of risk presented by the customer, transaction, or relationship.

• Higher-risk situations require Enhanced Due Diligence (EDD)
• Lower-risk situations may allow Simplified Due Diligence (SDD)

Enhanced Due Diligence (EDD) — Higher-Risk Examples

EDD will be applied where the risk of money laundering or terrorist financing is greater. This may include:

• Large or unusual transactions where the source of funds is unclear
• Investors based outside the UK, particularly in jurisdictions with weak AML controls
• Politically Exposed Persons (PEPs) (e.g., senior government officials or their associates)
• Transactions involving cash deposits over regulatory thresholds
• Complex ownership structures or trusts that make it difficult to identify the ultimate beneficial owner

EDD measures may include:

• Obtaining additional proof of ID and address
• Requesting bank statements, payslips, or tax returns to verify source of funds
• Requiring information on the purpose of the investment and expected transaction activity
• Senior management approval before proceeding with the relationship

Simplified Due Diligence (SDD) — Lower-Risk Examples

SDD may be applied where the risk of money laundering is considered low, and legislation permits lighter checks. Examples include:

• Investors with a long-standing relationship with Swift Sale Properties Ltd and a clear transaction history
• Transactions involving small amounts where the risk of financial crime is negligible
• Counterparties that are regulated financial institutions (e.g., a UK bank)

SDD measures may include:

• Verifying ID and address using standard documents only
• Not requiring additional information about source of funds (unless red flags arise)
• Ongoing monitoring kept proportionate to the low-risk nature of the relationship

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4. Record Keeping

All records relating to CDD, source of funds, and any AML-related documentation will be securely retained for a minimum of 5 years in line with UK law.

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5. Suspicious Activity Reporting

• The Company has appointed a Money Laundering Reporting Officer (MLRO): Mr Owen Lloyd Taylor (Director of Swift Sale Properties Ltd).
• All staff and contractors are required to report any suspicious activity immediately to the MLRO.
• The MLRO will assess and, if appropriate, submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).

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6. Reporting Obligations

Swift Sale Properties Ltd is legally obligated to cooperate with relevant authorities and will report any knowledge or suspicion of money laundering, terrorist financing, or criminal property to the NCA as required by law.

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7. Training

All staff and contractors involved in property transactions or investment activities will receive anti-money laundering training appropriate to their role.

• Training will be provided on induction.
• Updates will be given when there are significant changes in legislation or regulatory requirements.

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8. Non-Compliance

Failure to comply with this AML Policy may result in:

• Disciplinary action or termination of employment/contract
• Reporting to the relevant authorities
• Legal and/or criminal consequences

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9. Governing Law

This Anti-Money Laundering Policy is governed by and shall be construed in accordance with the laws of the United Kingdom.