Client AML protocol

i) Investors (Projects)
For direct investors we require two pieces of verified identification, of which at least one must show a photograph and at least one must confirm the investor’s current address. We retain copies of the ID, held securely and for as long as required, in line with GDPR (2018) retention requirements. We also require investors to self-certify as either HNWI or sophisticated investors.

For indirect investors (those who invest via a broker) we require the broker to carry out AML checks, retain the documentation as necessary and in compliance with AML and GDPR requirements. We request written confirmation from the broker that AML requirements have been met.

ii) Operating Partners
As an investment company, Resurgam Asset Management holds assets and works with partners to deliver the repurposing project and subsequent operation of the buildings. Resurgam Asset Management carries out due diligence on its operating partners, including identification verification of the directors of the operating partner companies and review of the companies’ filing at Companies House.

iii) Operating Business Clients
Identification verification of the end clients of the businesses operating in the assets is the responsibility of the operating partners. Resurgam Asset Management reviews and audits the operating partners’ AML processes.