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Code of Practise

Commitment to Compliance

Explore the essential regulations and policies that guide our operations, ensuring transparency and trust in every transaction.

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Anti Money Laundering

GDPR Compliance

Privacy and Disclaimer

Complaints Procudure

Contact Us
TPO Code of Practice - residential

Anti Money Laundering Regulations

Your Detailed Guide to AML in Real Estate

Stonelink International is committed to the highest standards of compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended 2019, 2024, and 2026).

Money laundering is the process by which “dirty” money (proceeds of crime) is made to look “clean.” The property market is a high-risk sector for this activity. To prevent our services from being used for financial crime, we conduct mandatory Customer Due Diligence (CDD) on all parties involved in a transaction.

1. Selling a Property

If you are selling a property through us, we are legally required to verify your identity and proof of ownership before we can begin marketing your home.

  • Identity Verification: We require a valid government-issued photo ID (Passport or UK Driving License) and a recent utility bill or bank statement (less than 3 months old) as proof of address.

  • Proof of Ownership: We will conduct a check with HM Land Registry to ensure the person instructing the sale is the legal owner.

  • Beneficial Owners: If the property is held in a company name or trust, we must identify all “beneficial owners” (those owning or controlling 25% or more of the entity).

2. Buying a Property

For buyers, AML checks are performed once an offer is made or accepted. We cannot progress a sale to “Subject to Contract” status without these.

  • Source of Funds (SoF): You must provide evidence of how you intend to fund the purchase (e.g., bank statements showing savings, a mortgage in principle, or evidence of a property sale).

  • Source of Wealth (SoW): In high-risk or high-value cases, we may ask for further evidence of how your overall wealth was generated (e.g., inheritance, business profits, or long-term investments).

  • Sanctions Screening: All buyers are screened against the UK Sanctions List. We are prohibited from dealing with any individuals or entities subject to financial sanctions.

3. Leasing a Property (Landlords & Tenants)

Important Update (May 2025/2026): Previously, AML checks only applied to rents over £8,300/month (€10,000). The threshold has been removed. All tenancies, regardless of value, now require AML and Sanctions screening.

For Landlords:

  • Identity & Ownership: Same as the “Selling” process—we must verify you are the legal owner and confirm your identity.

  • Ongoing Monitoring: We must ensure that the rental income is being paid into an account held by the legal landlord.

For Tenants:

  • ID & Right to Rent: While “Right to Rent” is a separate check, AML regulations now require us to screen all tenants against financial sanctions lists.

  • Third-Party Payments: If a parent or employer is paying the rent/deposit, they must also undergo identity and source of funds verification.

🚩 Reporting & Compliance

Our staff are trained to identify “Red Flags,” such as:

  • Unusual urgency to complete a transaction.

  • Funds coming from high-risk jurisdictions.

  • Reluctance to provide identity documents.

If we suspect money laundering, we have a legal obligation to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA). Under “Tipping Off” laws, we are strictly prohibited from informing you if a report has been made.

Proof of Funds” checklist

This updated guide includes the strict requirements for complex entities like offshore firms and trusts. Since 2023, the Register of Overseas Entities (ROE) at Companies House is a mandatory check for any foreign entity buying or selling UK property.

🏢 Enhanced Due Diligence for Complex Entities

When a property is being bought, sold, or leased by an entity rather than an individual, we must “look through” the structure to identify the individuals who ultimately own or control it.

1. Limited Companies (UK)

  • Proof of Registration: Certificate of Incorporation and Memorandum & Articles of Association.

  • Proof of Control: A current “Confirmation Statement” (Annual Return) showing directors and shareholders.

  • Beneficial Owners: We must verify the identity and address of all Ultimate Beneficial Owners (UBOs) who own or control 25% or more of the shares or voting rights.

2. Partnerships & LLPs

  • Partnership Agreement: A copy of the formal agreement.

  • Verification: We must verify the identity of at least two partners and any individual who exercises significant control over the partnership.

3. Trusts

Trusts are considered high-risk due to their potential for anonymity. We require:

  • The Trust Deed: To identify the Settlors, Trustees, and Beneficiaries.

  • The Protector (if any): Any individual with the power to appoint or remove trustees.

  • Verification: AML checks (ID and Address) for all named Trustees and any Beneficiaries with a vested interest of 25% or more.

  • TRS Registration: Proof that the trust is registered with the HMRC Trust Registration Service (TRS).

4. Offshore & Overseas Entities

Strict Compliance Note: Since the Economic Crime Act 2022, any overseas entity wishing to buy, sell, or transfer UK land must be registered on the Register of Overseas Entities at Companies House.

  • ROE ID Number: We cannot progress a transaction without a valid Overseas Entity ID.

  • Local Documentation: Equivalent of a Certificate of Incorporation (e.g., Certificate of Incumbency) from the home jurisdiction.

  • Enhanced Due Diligence (EDD): If the entity is based in a “High-Risk Third Country” (as defined by the UK Government), we are legally required to perform deeper checks into the Source of Wealth of the UBOs.

💰 Source of Funds & Wealth Checklist

For all transactions, we must verify where the money came from. Proof of Funds (showing the money exists) is not the same as Source of Funds (proving how it was earned).

Source of Funds Required Documentation
Personal Savings 6 months of bank statements showing the gradual build-up of funds.
Property Sale A copy of the completion statement from your solicitor and a bank statement showing the receipt of funds.
Inheritance A copy of the Will or a letter from the Executors/Solicitors, plus proof of receipt.
Gifted Funds A signed Gifted Deposit Declaration from the donor, plus their ID and 6 months of their bank statements.
Company Profits Latest audited accounts, dividend certificates, or a letter from a regulated accountant.
Sale of Shares A copy of the share release schedule and a bank statement showing receipt.

⚠️ Important Considerations

  • No Cash: We do not accept cash payments for property transactions or deposits.

  • Third-Party Payments: Funds must generally come from an account in the name of the party involved in the transaction. If a third party is paying, they must undergo full AML screening.

  • Tipping Off: If we request more information, it is a legal requirement. We cannot “look the other way.”

Further Information

If you have any questions about our Anti Money Laundering Policy and our approach, please phone us direct on: +44 (0) 207 993 4081 or contact us.

HMRC Anti-Money Laundering Supervision Registration Number:
XYML00000108367.

This website is the property of Stonelink International (London) Limited, Linen Hall, 162 – 168 Regent Street, London, W1B 5TD, United Kingdom; Company No: 08244749; VAT No: 188 4943 50.

GDPR Overview

General Data Protection Regulation (GDPR)

This GDPR policy reflects the latest legal framework as of February 2026, incorporating the Data (Use and Access) Act 2025 (DUAA), which officially came into force this month.

The DUAA has simplified some aspects of “Legitimate Interests” but introduced stricter requirements for complaints procedures and automated decision-making (e.g., automated tenant referencing).

🔒 Privacy & Data Protection Policy

Last Updated: February 2026

At Stonelink International (London) Limited, we take our responsibilities under the UK GDPR and the Data (Use and Access) Act 2025 seriously. This policy explains how we collect, use, and protect your personal data across our sales, lettings, and management services.

1. The Data We Collect

We collect personal information necessary to facilitate property transactions and meet legal obligations:

  • Sellers & Landlords: Contact details, proof of ownership, financial info for receiving funds, and AML identity documents.

  • Buyers & Tenants: Contact details, financial qualifications (Source of Funds), employment history, and references.

  • Website Users: IP addresses and browsing behavior via cookies (see our Cookie Policy).

2. Lawful Basis for Processing

Under the 2025 Act, we process data using the following legal grounds:

  • Contractual Necessity: To perform the service you hired us for (e.g., marketing your home or managing a tenancy).

  • Legal Obligation: Specifically for Anti-Money Laundering (AML) checks and Right to Rent verifications.

  • Recognised Legitimate Interests: The 2025 Act now provides “recognised” interests for crime prevention and safeguarding. We use this to screen for fraud and ensure the security of our staff during viewings.

  • Consent: We will only send you marketing/newsletter communication if you have opted-in. An option to opt-out or modify your subscription preferences is integrated into every communication we send.

3. Data Sharing

We only share your data with trusted third parties where necessary:

  • Solicitors & Conveyancers: To facilitate the legal transfer of property.

  • Referencing Agencies: To verify tenant suitability.

  • Contractors: To carry out essential repairs (for managed properties).

  • Government Bodies: HMRC or the National Crime Agency where legally required.

4. Automated Decision-Making (ADM)

If we use automated systems for initial tenant or buyer vetting, you have the right under the 2025 Act to:

  • Be informed that an automated decision was made.

  • Request human intervention to review the decision.

  • Contest the outcome.

5. Your Rights & Complaints

You have the right to access, rectify, or erase your data (the “Right to be Forgotten”), subject to legal retention periods (usually 6 or 7 years for financial and AML records).

New for 2026: Complaints Procedure Under the DUAA 2025, we have a formal process for data complaints:

  1. Submission: Send your complaint to admin (@) stonelinkinternational (dot) com or Contact Us

  2. Acknowledgment: We will acknowledge your complaint within 30 days.

  3. Resolution: We will provide a full response without undue delay. If you are unsatisfied, you have the right to escalate to the Information Commissioner’s Office (ICO). Our ICO registration number is Z3468085.

Further Information

If you have any questions about the GDPR policy or our Disclaimer or Privacy Policy or wish to terminate the use of any information we have collected from you, please phone us direct on: +44 (0) 207 993 4081 or contact us. Our policy and your use of this website is governed by and construed in accordance with the laws of England and Wales.

This website is the property of Stonelink International (London) Limited, Linen Hall, 162 – 168 Regent Street, London, W1B 5TD, United Kingdom; Company No: 08244749; VAT No: 188 4943 50.

 

Privacy Policy

🔒 Privacy Policy

Last Updated: February 2026

At Stonelink International (London) Limited, we are committed to protecting the privacy and security of our clients’ personal and financial data. This policy outlines how we collect, process, and protect your information in accordance with the UK GDPR and the Data (Use and Access) Act 2025.

1. Data Controller

The data controller for your information is Stonelink International (London) Limited of Linen Hall, 162 – 168 Regent Street, London, W1B 5TD, registered with the Information Commissioner’s Office (ICO) under registration number: Z3468085. Our company registration number is: 08244749

2. Information We Collect

To provide our bespoke real estate advisory, sales and retained search services, we collect:,

  • Identity Data: Full name, date of birth, and nationality (for AML and Right to Rent checks).

  • Contact Data: Personal/business email, phone numbers, and residential addresses.

  • Financial Data: Bank statements, source of wealth documentation, and mortgage agreements.

  • Entity Data: For corporate clients, we collect Articles of Association and Register of Overseas Entities (ROE) details.

  • Technical Data: IP addresses and browsing behavior via cookies to improve our website experience.

3. How We Use Your Data (Lawful Basis)

Under the 2025 Act, we process your data under the following recognized bases:

  • Contractual Necessity: To perform our duties as your retained advisor/consultant (e.g., negotiating property acquisitions/sales).

  • Legal Obligation: To satisfy mandatory Anti-Money Laundering (AML) and Terrorist Financing regulations.

  • Recognised Legitimate Interests: For the prevention of fraud, ensuring the safety of our staff during private viewings, and marketing our services to you (where you have a reasonable expectation of such contact).

4. Data Sharing & International Transfers

We do not sell your data. We only share information with:

  • Professional Advisers: Solicitors, surveyors, and mortgage brokers involved in your transaction.

  • Verification Services: Third-party AML and identity check providers (e.g., Thirdfort/Credas).

  • Overseas Transfers: If you are an international client, we ensure all data transfers outside the UK are protected by Standard Contractual Clauses (SCCs) or adequacy regulations.

5. Data Retention

We retain personal data for as long as necessary to fulfill the purposes we collected it for, including any legal, accounting, or reporting requirements. Under UK AML law, this is typically 7 years following the end of our business relationship.

6. Your Rights (Updated for 2026)

You have the following rights regarding your data:

  • Access & Portability: Request a copy of your personal data.

  • Correction/Erasure: Request that we fix or delete your data (subject to legal retention limits).

  • Automated Decision Making: Under the 2025 Act, you have the right to request human intervention if an automated system (e.g., digital referencing) produces a negative result.

  • Complaints: If you have a concern, please contact our Data Protection Officer at admin (@) stonelinkinternational (dot) com or Contact Us. If we do not resolve it within 30 days, you may escalate to the Information Commissioner’s Office (ICO).

Further Information

This Privacy Policy and your use of this website, is governed by and construed in accordance with the laws of England and Wales.

If you have any questions about this policy or wish to terminate the use of any information we have collected from you, please phone us on + 44 (0) 207 993 4081 or send an email by filling in the form below or contact us today.

This website is the property of Stonelink International (London) Limited, Linen Hall, 162 – 168 Regent Street, London, W1B 5TD, United Kingdom; Company No: 08244749; VAT No: 188 4943 50.

Disclaimer

Website Disclaimer

⚖️ Legal Disclaimer & Terms of Use

Last Updated: February 2026

1. Accuracy of Property Particulars

While  Stonelink International (London) Limited endeavors to ensure that all property marketing materials, virtual tours, and descriptions are accurate, they are intended as a guide only.

  • Consumer Protection: In accordance with the Digital Markets, Competition and Consumers Act 2024, we disclose all “Material Information” known to us. However, these particulars do not constitute an offer or contract.

  • Verification: All measurements, floorplans, and distances are approximate. We strongly advise all prospective buyers and tenants to satisfy themselves by inspection or otherwise as to the correctness of each statement.

  • Services & Appliances: We have not tested any apparatus, equipment, fixtures, fittings, or services (including heating and plumbing). It is the responsibility of the buyer or tenant to check their working condition.

2. Material Information Disclosure

We make every effort to include Part A, B, and C material information (including tenure, council tax, utilities, flood risk, and structural issues) in our listings.

  • Where information is provided by a third party (e.g., the seller or a local authority), we cannot guarantee its 100% accuracy.

  • If a specific piece of information is critical to your decision to view or purchase/lease, please contact us for written verification before traveling to the property.

3. Financial Advice & Surveying

Stonelink International (London) Limited are property professionals, not financial advisors, solicitors, or structural surveyors.

  • Any information regarding potential rental yields, mortgage rates, or tax implications is for illustrative purposes only.

  • We recommend that you consult with a regulated professional (FCA for finance, RICS for surveys, or SRA for legal) before making a “transactional decision.”

4. Website Content & External Links

  • Non-Reliance: The content on this website is provided for general information only. It is not intended to amount to advice on which you should rely.

  • External Sites: Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites.

5. Professional Memberships & Redress

In compliance with the Consumers, Estate Agents and Redress Act, we are members of:

  • Redress Scheme: The Property Ombudsman
    Our TPO Agent Membership ID: D7618-0

  • Client Money Protection (CMP): Client Money Protect
    Our Client Money Protect (CMP) Membership number: CMP003887

  • Information Commissioners Office (ICO): Our ICO registration number is Z3468085.

  • AML Supervision: We are supervised by HMRC for Anti-Money Laundering purposes. HMRC Anti-Money Laundering Supervision Registration Number: XYML00000108367

     

Further Information

This DISCLAIMER and your use of this website, is governed by and construed in accordance with the laws of England and Wales. If you have any questions about this policy or wish to terminate the use of any information we have collected from you, please phone us on + 44 (0) 207 993 4081 or send an email by filling in the form below or contact us today.

This website is the property of Stonelink International (London) Limited, Linen Hall, 162 – 168 Regent Street, London, W1B 5TD, United Kingdom; Company No: 08244749; VAT No: 188 4943 50.

 

Compliance Procedure

Submitting a Complaint

⚖️ Complaints Handling Procedure (CHP)

Our Commitment to Service Excellence

At Stonelink International (London) Limited, we pride ourselves on providing a bespoke, world-class service. However, we recognise that occasionally things may not go as planned. We take all complaints seriously and use them as an opportunity to improve our fiduciary standards.

Stage 1: Formal Written Complaint

If you have a complaint, please put it in writing, including as much detail as possible.  We will then respond in line with the timeframes set out below (if you feel we have not sought to address your complaints within eight (8) weeks, you may be able to refer your complaint to the Property Ombudsman to consider without our final viewpoint on the matter).

Where your complaint is initially made orally you will be requested to send a written summary of your complaint to the person dealing with it.

Complaints Address

Upon filing the complaint, the first point of contact to deal with complaints, will be the relevant person to take on the case. Please send details are set out below:

  • Email: admin (@) stonelinkinternational (dot) com or send an email through our contact us page.

  • Address: Stonelink International (London) Limited
    Linen Hall, 162 – 168 Regent Street, London, W1B 5TD, United Kingdom

Stage 2: Internal Investigation

Your complaint will be investigated by a senior member who was not directly involved in the initial matter. A formal written outcome of our investigation will be sent to you within 15 working days of our acknowledgment letter.

In exceptional cases where further investigation is required, we will keep you informed of our progress.

Stage 3: Final Viewpoint

  • If, at this stage, you are still not satisfied, you should contact us again and we will arrange for a separate review to take place by a senior member of staff.
  • We will write to you within fifteen (15) working days of receiving your request for a review, confirming our final viewpoint on the matter.
  • If you are still not satisfied with our final viewpoint (or more than eight (8) weeks has elapsed since the complaint was first made) you can request an independent review from The Property Ombudsman without charge.

Stage 4: Independent Redress (The Property Ombudsman)

If you are still not satisfied with our Final Viewpoint, or if more than 8 weeks have passed since you first complained and the issue remains unresolved, you can refer your complaint to The Property Ombudsman (TPO) for an independent review.

Please Note: You must refer your complaint to The Property Ombudsman within 12 months of receiving our Final Viewpoint Letter. The Property Ombudsman requires that all complaints are addressed through this in-house complaint procedure, before being submitted for an independent review.

Further Information

This website, is governed by and construed in accordance with the laws of England and Wales. If you have any questions about our privacy policy or wish to terminate the use of any information we have collected from you, please phone us on + 44 (0) 207 993 4081 or send an email by filling in the form below or contact us today.

This website is the property of Stonelink International (London) Limited, Linen Hall, 162 – 168 Regent Street, London, W1B 5TD, United Kingdom; Company No: 08244749; VAT No: 188 4943 50.

Need More Information?

Should you have any questions or need further assistance regarding our compliance with the Anti Money Laundering Regulations, GDPR, Privacy Policy, Disclaimer, or Complaints Procedure, we’re here to help. Reach out to us at Stonelink International, and let us guide you through the details. Your peace of mind is our priority.

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