Last updated: 15/01/26

1. Introduction

This Anti-Money Laundering (AML) Policy sets out the controls implemented by CDJ Deal Sourcing to prevent money laundering and terrorist financing. The policy ensures the business meets its obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

CDJ Deal Sourcing Limited operates as a property deal sourcing business, introducing investment opportunities in UK residential and/or commercial property to UK investors in return for a sourcing fee. The business does not handle client funds or complete property transactions on behalf of clients. Despite not handling client funds, the nature of our business activities presents inherent money laundering risks, which we mitigate through robust AML controls.

2. Roles and Responsibilities

We have a Nominated Officer for AML who is responsible for oversight of AML compliance, reporting suspicious activity, training, and liaison with HMRC and the National Crime Agency (NCA).

3. Risk Assessment

We assess our business operations against money laundering risks and identify appropriate mitigations, which are subsequently captured within our company procedures. This risk assessment is formally recorded and periodically reviewed to ensure we develop it in line with any changes to our service offering and learn lessons from our ongoing business operations.

4. Procedural Controls

We implement the following procedural controls to mitigate money laundering risks:

1. Limitations of our service, i.e. our current service offering is limited to UK-based individuals and UK limited companies only.

2. Client due diligence checks which include proof of identification and address. These are tailored for UK individuals and companies in-line with our current service offering.

3. Source of funds checks and payment controls / verification.

4. Suspicious activity reporting.

5. Record Keeping

All client records associated with AML compliance will be retained electronically for 5 years in accordance with current legislation, available for any potential future investigations. These records will not be used for any other purpose.

6. Training

We are committed to developing and maintaining our understanding of AML legislation to ensure we are aware of the risks of money laundering and terrorist financing and our responsibilities. We maintain training records that include AML legislation training.