Financial Crime Prevention & Anti-Money Laundering

1. Purpose

House of Luchini Ltd is committed to conducting its business with honesty, integrity and transparency. We take reasonable and proportionate steps to reduce the risk of money laundering, terrorist financing, fraud, bribery and other forms of financial crime.

Whilst House of Luchini Ltd is not a regulated financial institution, we recognise our responsibility to understand who we do business with, protect client funds, verify payment information where appropriate and maintain robust internal controls.

This policy sets out the procedures followed by the Company to minimise financial crime risks across its operations.

2. Scope

This policy applies to:

• Directors
• Employees
• Contractors
• Consultants
• Anyone acting on behalf of House of Luchini Ltd

The policy applies to all property management activities undertaken by the Company.

3. Risk-Based Approach

House of Luchini Ltd adopts a proportionate, risk-based approach to financial crime prevention.

The Company will consider the level of risk presented by:

• New property owners.
• Corporate clients.
• Direct payment arrangements.
• Changes to bank account details.
• Unusual payment requests.
• Complex ownership structures.
• Transactions that appear inconsistent with normal business activity.

Higher-risk situations may require additional verification before services commence.

4. Client Due Diligence

Before entering into a Property Management Agreement, House of Luchini Ltd may undertake reasonable checks to verify the identity of the client.

Depending on the circumstances, these checks may include:

• Proof of identity.
• Proof of address.
• Confirmation of property ownership.
• Verification of company details where applicable.
• Verification of authorised representatives.

Additional information may be requested where circumstances reasonably require it.

5. Payment Controls

To reduce the risk of fraud and financial crime, House of Luchini Ltd will:

• Verify owner bank details before making payments.
• Independently confirm any request to change payment instructions.
• Maintain accurate payment records.
• Use secure banking methods wherever possible.
• Investigate unusual or unexpected payment requests before processing.

The Company does not normally accept cash payments. Any exception must receive prior approval from a Director and be appropriately documented.

6. Booking & Guest Verification

House of Luchini Ltd primarily receives bookings through established online travel platforms, which operate their own customer verification and payment security processes.

For direct bookings, the Company may request appropriate identification and supporting information where considered necessary to reduce fraud or financial crime risks.

7. Fraud Prevention

House of Luchini Ltd operates a number of internal controls designed to reduce the risk of fraud, including:

• Verification of ownership before onboarding new properties.
• Secure handling of client information.
• Independent verification of changes to bank details.
• Monitoring unusual booking patterns.
• Restricting access to financial information to authorised personnel only.
• Maintaining separation of duties where reasonably practicable.

8. Reporting Concerns

Any employee or contractor who becomes aware of suspicious, fraudulent or potentially unlawful activity must report their concerns to a Director as soon as reasonably practicable.

Where appropriate, the Company will seek independent legal or professional advice and will comply with any legal reporting obligations that apply.

Employees who report concerns in good faith will not suffer any detriment for doing so.

9. Record Keeping

House of Luchini Ltd will maintain appropriate business records relating to:

• Client identification (where obtained).
• Property management agreements.
• Financial transactions.
• Payment records.
• Internal investigations, where applicable.

Records will be retained in accordance with the Company’s Data Retention Policy and applicable legal requirements.

10. Staff Responsibilities

All staff are expected to:

• Act honestly and with integrity.
• Follow Company procedures.
• Protect confidential information.
• Report suspicious activity promptly.
• Complete any compliance training required by the Company.

11. Prohibited Activities

House of Luchini Ltd will not knowingly:

• Assist money laundering or financial crime.
• Accept funds believed to originate from criminal activity.
• Process fraudulent payments.
• Provide false or misleading information to clients, banks or public authorities.
• Circumvent legal or regulatory requirements.

Any breach of this policy may result in disciplinary action and, where appropriate, referral to the relevant authorities.

12. Policy Review

This policy will be reviewed annually, or sooner if there are significant changes to legislation, business operations or identified risks.