Compliance Corner

Financial Regulations

As per UK government guidance, from May 2025:

• All letting agents will be subject to expanded reporting obligations
• All banks must verify who they hold client money for
• Reporting requirements apply regardless of rental value
• No monetary threshold for reporting obligations

Client Money Protection

As per government requirements:

• Required for property agents in England carrying out letting agency or property management work
• Must belong to an approved CMP scheme
• Must display certificate prominently in branch and on website
• Must provide copy of certificate to anyone who reasonably requires it
• Not required for:
  • Block management companies
  • Right to Manage (RTM) companies
  • Property maintenance companies who don't handle rental income

Safeguarding of Funds

CalmonyPay Account (Modulr)

• Modulr FS Ltd (FRN: 900573) is licensed as an authorised E-Money Institution (EMI) and regulated by the Financial Conduct Authority (FCA)
• Calmony is a trading name of agentOS Proptech Group Ltd, registered as a PSD agent (FSA reference 850923)
• Payment services regulated under Payment Services Regulations (PSRs)
• 100% of customer funds segregated from Modulr's own funds
• Funds safeguarded in Bank of England account
• Additional "own funds" held to value of 2% of safeguarded balance
• Full balance protected with no upper limit
• Unlike bank accounts which are limited to £85,000 FSCS protection, and from 1th December 2025 increased to £120,000
• Protection mechanism ensures orderly wind down if required
• Subject to same money laundering and Proceeds of Crime Act obligations as banks

Griffin Account

• Client funds held in segregated accounts at Bank of England
• Regulated by the Financial Conduct Authority (FCA)
• Protected by safeguarding regulations
• Full balance protected
• Regular monitoring and compliance checks

Compliance Requirements by Account Type

CalmonyPay Account (Modulr)

Existing Payees When Opening Account:

• Calmony will grandfather AML exempt your existing payees
• These will show as 'Not AML Checked' with 'Historic AML Exemption' status

Excluded from Grandfathering:

• Overseas nationals
• Landlords with no NRL exemption number - These payees will require new AML checks

AML checks required for new payees:

• Can request AML exemption for:
  • Limited Companies
  • Local Authorities
  • Deposit Schemes
  • Trading/business accounts using details from your application/DD form
  • Tenants (for return payments matching incoming payment details)
• To request exemption:
  • Select 'Actions' on payee record
  • Choose 'Request Calmony AML Exemption'
  • Provide required documentation
  • Wait for confirmation

Griffin Account

• All landlords must complete Griffin Verify process
• No exemptions available for landlords
• Must provide:
  • Valid photo ID
  • Proof of address dated within 3 months
  • Residential address (not property addresses they own)
  • Bank account details matching their ID

Overseas Landlords

• UK residential address required for Griffin verification
• Options available:
  • Nominate UK-based individual through tenancy addendum
  • Use letting agent as nominated UK representative
• Cannot verify landlords with overseas residential address

Record Keeping

• All verification documents stored securely
• Bank statements generated monthly
• Transaction history maintained
• Payment records include full audit trail

Payment Compliance

• Cannot set up direct debits from client accounts
• International payments subject to restrictions
• All payments traceable through unique references
• Failed payments require investigation and documentation

Where to Find Help

• Compliance queries: Contact [e-mail]
• CMP certification: Contact your scheme provider
• AML questions: Contact [e-mail]
• Response within 1 working day for Calmony support queries