A guide for Real Estates Money laundering A guide for Real Estates

Contents Expectations Identity Requirement Red Flags Red Flags (continue)

Expectations DIA expects real estate agents to: 1. Know your ML/TF risks 2. Know what to expect from your AML/CFT supervisor 3. Know how to apply the AML/CFT Act to your business 4. Know your compliance requirements 5. Know your client 6. Know the ML/TF red flags 7. Know where to get support Expectations Consider talking about: Criminalization The role of financial institutions Value of enforcement costs and associated privacy concerns Global organizations

Identity requirements When standard CDD applies, the following identity information must be gathered about a client, the beneficial owner(s), and a person acting on behalf of a client: • Full name • Date of birth • If the person is not the client, the person’s relationship to the client • Address or registered office • Company identifier or registration number Identity requirements

There is significant and unexplained geographic distance between the real estate agent and the location of the client The client/customer invests in real estate at higher or lower prices than expected by the market The client is a business or a trust whose organisational structure is unusual or excessively complex Red Flags

Red Flags A property is bought and sold in quick succession The client is selling for less than the purchase or market price and/or is disinterested in obtaining a better price The client shows interest in purchasing property without normal levels of interest in price, characteristics of the property, or other details The client offers an unusually high price for property and is not interested in obtaining a better price for the real estate agency work There is an unusual involvement of third parties Red Flags