1. Purpose & Scope
The purpose of this Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy is to establish clear internal guidelines to prevent the ColomboHomes platform from being used as a conduit for laundering proceeds of unlawful activity, facilitating terrorist financing, or executing fraudulent real estate transactions.
This policy applies to all property enquiry facilitations, client consultations, owner representation mandates, and broker engagements coordinated through ColomboHomes within the territory of Sri Lanka.
2. Commitment to Preventing Illicit Activity
We uphold a strict zero-tolerance stance toward financial crime. Our operational framework incorporates risk-based due diligence to safeguard property buyers, sellers, landlords, and consultants against association with unlawful financial flows.
3. Customer Identification & Know Your Customer (KYC)
Before facilitating formal negotiations, contracts, or high-value viewing access, ColomboHomes requires verified identification of all principal parties:
- Valid National Identity Card (NIC) for Sri Lankan citizens.
- Valid Passport and visa endorsement for foreign nationals or non-resident Sri Lankans.
- Proof of residential address (e.g., utility bill or bank statement within 3 months).
- Verified active telephone number and email address.
- Certificate of Incorporation (Form 1 / Form 20 in Sri Lanka).
- Articles of Association and registered business address.
- Board resolution appointing the authorized negotiating signatory.
- Identification documents for all directors and key managing executives.
4. Identification of Ultimate Beneficial Ownership (UBO)
Where property transactions involve corporate vehicles, trusts, partnerships, or nominees, ColomboHomes takes reasonable steps to identify the natural person(s) who ultimately own or control the legal entity (typically holding 25% or more of voting rights or equity). Anonymous company structures and unverified bearer share arrangements are strictly excluded from our brokerage matchmaking services.
5. Risk-Based Assessment (RBA)
We apply a risk-based methodology, scaling the depth of our verification according to the assessed risk profile of the transaction:
- Standard Risk: Conventional transactions involving resident individuals purchasing residential units with standard mortgage financing from licensed Sri Lankan commercial banks.
- Enhanced Due Diligence (EDD): High-value transactions involving non-residents, complex multi-layered offshore corporate vehicles, Politically Exposed Persons (PEPs) or their family members, and high-value off-market cash settlements.
6. Verification of Source of Funds & Wealth
In coordination with the parties’ appointed notaries and banking institutions, ColomboHomes encourages full transparency regarding the origin of property acquisition capital. Where required by prudent due diligence, purchasers may be asked to substantiate that funds originate from lawful commercial activities, verified employment, inheritance, bank credit facilities, or inward foreign investment remittances channeled through authorized Sri Lankan Inward Investment Accounts (IIA).
7. Suspicious Activity Indicators (Red Flags)
Our consultants are trained to identify and report red flags that may indicate potential financial misconduct, including:
- Reluctance, refusal, or significant delay in providing valid identification credentials or title documentation.
- Requests to record a deed purchase price substantially below or above reasonable market value without commercial justification.
- Proposals to settle significant balances in unverified physical cash, third-party uncrossed checks, or untraceable foreign instruments.
- Purchasers showing total indifference to property inspection, location, structural condition, or title caveats.
- Frequent last-minute changes to buyer names, corporate entities, or executing signatories immediately prior to deed attestation.
8. Prohibited Transactions & Sanctions Screening
ColomboHomes will not facilitate property transactions, list properties, or coordinate with any individual, entity, or intermediary that is:
- Listed on applicable United Nations Security Council (UNSC) sanctions lists.
- Designated under Sri Lankan government anti-terrorism or targeted financial sanctions regulations.
- Operating through unverifiable shell companies or disguised nominee arrangements designed to obscure ownership.
9. Record Retention
To support transparency and facilitate statutory audits when required by law, ColomboHomes maintains records of client identification, enquiry documentation, written property mandates, and consultation correspondence for a minimum period of five (5) years following the conclusion of the business relationship. Records are stored securely and protected against unauthorized access.
10. Cooperation with Statutory Authorities
ColomboHomes will fully cooperate with lawful requests, orders, and inquiries issued by authorized Sri Lankan state authorities, including law enforcement agencies, the judiciary, and the Financial Intelligence Unit (FIU) of the Central Bank of Sri Lanka, in accordance with applicable legal provisions and formal judicial processes.
11. Internal Controls & Staff Responsibilities
ColomboHomes requires all senior consultants, administrative personnel, and management to uphold rigorous standards of professional ethics. Staff are prohibited from advising, abetting, or “tipping off” clients who are subject to internal risk reviews, inquiry rejections, or official legal scrutiny.
12. Compliance Oversight & Contact
This policy is reviewed annually by executive management to incorporate evolving regulatory guidance and industry standards in Sri Lanka.
For inquiries regarding our compliance protocols, identification procedures, or documentation requirements, please reach our compliance coordination desk: