Anti-Money Laundering (AML) Policy

Last updated: 15 August 2026. This policy applies to FAPPNY, operated by Pole Star Property Services.

1. About this policy

FAPPNY is a business-to-business (B2B) verification and referral platform operated by Pole Star Property Services, a building surveying consultancy. This policy sets out our approach to anti-money laundering (AML), counter-terrorist financing (CTF), and know-your-business (KYB) obligations.

FAPPNY is not itself a regulated firm under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("MLR 2017") in the capacity of a listing platform. However, we take financial crime seriously and operate voluntary KYB controls that go beyond our strict legal minimum, in recognition of the regulated nature of the professions we list.

2. Scope

This policy applies to:

All professionals applying to join the FAPPNY directory
All professionals with an active Listing on the directory
All staff and contractors involved in the verification process

It does not apply to members of the public who use the directory to find professionals. Those users are subject to our Terms of Use and Privacy Policy.

3. Know Your Business (KYB) verification

Before any professional is listed on FAPPNY, we carry out a KYB check that includes:

Identity verification: Government-issued photo ID (passport, driving licence, or national identity card) for the individual applicant
Address verification: Proof of address dated within the last three months (utility bill or bank statement)
Business verification: Where applicable, Companies House registration confirmation and director identity checks
Regulatory body verification: Confirmation of active membership with the relevant professional body (RICS, SRA, FCA, RPSA, RIBA, CIOB, Gas Safe, NICEIC, or other as applicable)
Insurance verification: Current Professional Indemnity Insurance and Public Liability Insurance certificates showing adequate cover levels
Disqualified directors check: Companies House disqualified directors register search for all named directors
Insolvency check: Insolvency Service register search

These checks are repeated at annual renewal. A professional whose documents lapse or who fails to renew will have their Listing suspended until re-verification is complete.

4. Prohibited persons and businesses

We will not list, and will immediately remove, any professional or business that:

Is subject to a current disqualification order as a company director
Is subject to current insolvency proceedings (bankruptcy, liquidation, administration, or IVA)
Has been convicted of a financial crime offence, including fraud, money laundering, or bribery
Is subject to sanctions under UK, EU, or UN sanctions regimes
Has been struck off or prohibited from practice by their relevant regulatory body
Has submitted forged, altered, or materially misleading documents during the application or renewal process

5. Suspicious activity

We will report to the National Crime Agency (NCA) via a Suspicious Activity Report (SAR) where we have knowledge or reasonable suspicion that a listed professional is involved in money laundering or terrorist financing, in accordance with Part 7 of the Proceeds of Crime Act 2002 and the Terrorism Act 2000.

We will not tip off any individual or business that a SAR has been submitted or that an investigation is underway.

Members of the public who suspect that a professional listed on FAPPNY is involved in financial crime should contact the NCA directly at nationalcrimeagency.gov.uk or call Action Fraud on 0300 123 2040.

6. Obligations on listed professionals

Many professions listed on FAPPNY are themselves subject to AML obligations under MLR 2017. These include (but are not limited to): surveyors, conveyancers, estate agents, mortgage brokers, and financial advisers. By maintaining a Listing on FAPPNY, you confirm that:

You are registered with the appropriate AML supervisory authority for your profession (HMRC, RICS, SRA, FCA, or other)
You maintain a compliant AML programme, including customer due diligence (CDD) and enhanced due diligence (EDD) where required
You will carry out your own CDD/KYC checks on any client you acquire through FAPPNY, in accordance with your own regulatory obligations
You will not use FAPPNY to facilitate, promote, or assist in any transaction that constitutes or may constitute money laundering or terrorist financing

Failure to comply with these obligations is a breach of our Terms for Professionals and will result in immediate removal of your Listing.

7. Data retention

Verification documents submitted during the application and renewal process are retained for a minimum of five years from the date of submission, in accordance with the record-keeping requirements of the Money Laundering Regulations 2017. Documents are stored securely and access is restricted to authorised personnel only.

For full details of how we handle personal data, see our Privacy Policy.

8. Staff training and responsibility

All staff and contractors involved in the verification process receive training on AML obligations, red flags, and internal reporting procedures. The nominated Money Laundering Reporting Officer (MLRO) for FAPPNY is the principal of Pole Star Property Services.

9. Contact

If you have a question about this policy or wish to report a concern, please contact us at:

Pole Star Property Services
Email: [email protected]

This policy is reviewed annually and updated as required to reflect changes in legislation, regulatory guidance, and our business operations.