1. Introduction
Zero Down Lease is a group of companies comprising Leasehold Services Ltd, Leasehold Solicitors Ltd, and Leasehold Finance Ltd. We are required to comply fully with the Money Laundering Regulations 2017 and related legislation and are also required by law to obtain satisfactory evidence of the identity of our clients and any third parties involved in your matter.
Each Group Company maintains different regulatory oversight for compliance with the Money Laundering Regulations 2017:
Leasehold Services Ltd is registered with HM Revenue & Customs for anti-money laundering supervision (Registration Number: XZML00000204409).
Leasehold Solicitors Ltd is authorised and regulated by the Solicitors Regulation Authority (SRA No. 8011038) and is under the remit of the SRA for anti-money laundering supervision.
Leasehold Finance Ltd is registered with the Financial Conduct Authority as an Annex 1 Financial Institution for anti-money laundering supervision (Firm Reference: 1024784).
This means HMRC, the SRA and the FCA require us to carry out comprehensive identity checks and maintain robust processes to prevent financial crime. You can therefore rest assured that the processes are in place to protect your lease extension or freehold purchase from financial crime.
2. When We Need Your Information
We must verify your identity at the outset of our relationship. This means we need your identification documents before we can begin work on your matter. If this information is not provided promptly, your transaction may be delayed or we may have to withdraw our services. For leasehold enfranchisement matters, we require identification at the time you instruct us to proceed with your lease extension or freehold purchase. We cannot serve notices or take any substantive steps until identity verification is complete.
3. Individual Identification Requirements
For individual clients, we require two current forms of identification:
Primary identification must include photographic evidence such as a current passport or photographic driving licence.
Secondary identification must provide satisfactory proof of address such as a bank statement or utility bill dated within the last 3 months.
If you do not have a current passport or photographic driving licence, we can discuss alternative forms of identification. However, these alternatives may require additional verification steps.
4. Corporate Entity Requirements
The requirements for companies, partnerships, trusts and other entities are more complex. You will need to provide:
Documentation confirming the entity's existence, such as a certificate of incorporation and articles of association. We also require evidence of who the beneficial owners are and who has significant control over the entity.
A beneficial owner is someone who, through direct or indirect ownership or control, including through bearer shareholdings, owns more than 25% of the shares or voting rights, or who exercises control over the management of the entity.
For trusts, we require full details of the settlor, trustees, and beneficiaries. For partnerships, we need the partnership agreement and details of all partners.
5. Document Verification
Original documentation is required for verification purposes wherever possible. If you provide copies, they must be certified by an independent professional person such as a solicitor or accountant. The professional must confirm they have seen the original and the copy must be marked accordingly.
We reserve the right to use third-party services, including online identity verification companies, to verify any client's identity. This helps us meet our regulatory obligations efficiently while maintaining security.
6. Retention of Records
In line with the Money Laundering Regulations, we retain copies of your identification and verification documents in either paper or electronic form for 7 years after we cease our business relationship with you.
Where personal data is obtained solely to comply with Money Laundering Regulations, it will not be used for any other purpose without your consent, unless such additional use is required by law.
7. Ongoing Monitoring
For existing clients, we must check whether there have been any changes in your circumstances, such as a change of address, name, or in the case of corporate entities, any change in identity, structure, or beneficial ownership.
You should notify us of any such changes and provide relevant identification or evidence. We may periodically request updated information to ensure our records remain current.
8. Source of Funds and Wealth
We must verify the source of any funds being used for your property transaction. This applies to all funds, whether from your own resources or from third parties.
If you are purchasing with a mortgage, we require written confirmation from your lender. For cash purchases, we need bank statements or other evidence showing the funds are legitimately held in your name.
Funds received from third parties require the same level of identification and verification as required for clients themselves. We cannot accept funds from unverified third parties.
In some cases, we must also be satisfied as to your source of wealth. This means we may ask for an explanation of how you have acquired your overall financial position, not just the specific funds for this transaction.
9. Enhanced Due Diligence
We recognise that Politically Exposed Persons and their family members or known close associates may present higher money laundering risks. A PEP is an individual who is entrusted with prominent public functions, other than as a middle-ranking or more junior official.
When dealing with PEPs, we apply enhanced due diligence measures proportionate to the risk identified. For UK PEPs, we start from the position that they present a lower level of risk than non-UK PEPs, unless other risk factors are present. We obtain senior management approval for establishing or continuing business relationships with PEPs and take adequate measures to establish the source of wealth and source of funds involved in the proposed business relationship or transactions.
We apply enhanced due diligence measures when dealing with persons established in high-risk third countries as identified by the Financial Action Task Force (FATF). These measures include obtaining additional information on the customer and beneficial owner, obtaining information on the source of funds and wealth, obtaining information on the reasons for transactions, obtaining senior management approval, and conducting enhanced monitoring of the business relationship.
10. Reliance on Third Parties
Where permitted by law, we may rely on customer due diligence measures performed by eligible third parties. However, we remain ultimately responsible for compliance with our obligations. When relying on third parties, we immediately obtain all necessary information and enter into arrangements to obtain copies of identification and verification data upon request.
11. Professional Duties and Confidentiality
All Group Companies have a professional and legal duty to keep your affairs confidential. However, we are under a legal obligation to report to the National Crime Agency (NCA) if we have evidence or form a suspicion that a client is concerned with money laundering or terrorist financing.
We are explicitly prohibited by law from notifying you if we make such a report. If we make a report, we may have to suspend work on your matter or even terminate our relationship, and we cannot legally notify you of this fact or the outcome of the report.
We recognise that breaches of other regulations can create proceeds of crime. This includes unpaid stamp duty land tax, breaches of planning enforcement notices, operating without required licenses or permissions, breaches of building safety regulations, and fraudulent property valuations. Any benefit derived from such breaches may constitute criminal property.
11. Your Cooperation
You agree to cooperate with us to verify your identity, business structure (if applicable), organisational history (if applicable), and sources of income and funds. This cooperation is essential for us to discharge our legal and professional duties.
This may include attending our offices with identification and documentation for verification, though lawful alternatives can be considered if attendance is not possible. In some cases, we may need more detailed information such as bank statements and evidence of income.
We are grateful for our clients' understanding and patience while we discharge these professional duties.
12. Limitations of Liability
We will not be liable for any loss or damage arising from our compliance with legal and regulatory duties. This includes any delays or disclosures required in the context of anti-money laundering compliance.
We reserve the right to halt progress on your matter and temporarily retain any client money pending compliance with our professional duties, without further notice or explanation where we are legally prohibited from providing such information.
13. Additional Checks
We may request further documentation beyond what was originally requested if we deem it appropriate to meet our obligations under the Regulations. The nature and extent of checks may vary depending on risk factors associated with your matter.
As solicitors, Leasehold Solicitors Ltd must also perform conflict of interest checks for new cases against current and former clients.
14. Contact Us
If you have any questions about our anti-money laundering requirements, please contact:
Zero Down Lease
3rd Floor, 86-90 Paul Street
London, EC2A 4NE
Phone: +44 (0)20 3856 8300
Email: team@zerodown.lease
Last updated: 16th July 2025
