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Lexsure Publishes CQS Policy Updates for July 2023

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Did you miss any of these new and updated optional paragraphs that were added or edited in Lexsure's CQS Policy Template Documents database in recent weeks? Below is a list of examples of some of the latest suggested inclusions.

High-risk Third Countries

Your firm’s AML Policy should state that you apply EDD measures in any transaction or business relationship with a person established in a high-risk third country. This updated paragraph deals with the latest list of high risk countries.

Anti-Money Laundering Policy

5MLD Requirements - Reporting on a Company’s Beneficial Ownership

Addresses the Fifth Anti-Money Laundering Directive (5MLD) dealing with the requirement to report certain information discrepancies to Companies House.

AML Policy Template 

Submitting Better Quality Suspicious Activity Reports (SARs)

Submitting good quality SARs can reduce delays and help the UKFIU to quickly prioritise and process the report. Poor quality reporting can lead to unnecessary delays, particularly where a defence against money laundering has been sought, and can cause problems with your client, customer or supplier. Firms should recommend that firms adopt the advice set out in the NCA’s guidance on submitting better SARs.

CQS Anti-Money Laundering Policy Template

Implication of 35-Year Mortgages on Leasehold

Lenders have been increasing their minimum unexpired lease term requirements since 2008. The majority of lenders now set their calculations based on specifying a number of years remaining beyond the mortgage term. Given that 20% of mortgages are now 35 years or longer this directly impacts the mortgageability of certain leaseholds it is imperative that staff are aware that the underlying client needs to be advised accordingly.

Purchase of a Leasehold Policy

Borrower is a Charity

Draft section specifically dealing with the policy and procedures when the borrower is a charity  (exempt or registered).

CQS Dealing with Lenders Policy


















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