AML/CFT Obligations and Continuous Professional Development
AML/CFT core duties
Real estate agents are gatekeepers against money laundering and terrorist financing. Candidates must know customer due diligence (CDD): identifying and verifying clients and beneficial owners, understanding the source of funds, and establishing the purpose of the transaction. Enhanced due diligence applies to higher-risk clients such as politically exposed persons, complex ownership structures, and cash-heavy deals. Ongoing monitoring, record-keeping, and internal reporting are continuous duties.
Reporting and tipping-off
Suspicious transactions must be reported to the national financial intelligence unit promptly, without informing the client - tipping off is an offence. Agents must not proceed with a transaction they suspect is linked to criminal proceeds. Record retention typically spans several years after the relationship ends.
CPD obligations
Continuous professional development keeps knowledge current. Agents must complete the prescribed CPD hours per renewal cycle, covering topics such as AML/CFT, ethics, and regulatory updates, and retain certificates as evidence. CPD is verified at renewal.
Traps to watch
Questions often test whether CDD can be skipped for known clients - it cannot be fully waived, though simplified measures may apply. Another trap is treating suspicion reporting as optional or as something to discuss with the client first. Watch for distractors suggesting cash transactions need no source-of-funds check.
Worked example
A buyer insists on paying a large deposit in cash and refuses to explain its origin. Correct action: apply enhanced checks, decline to proceed, and file a suspicious transaction report without tipping off. Rule of thumb: know your client, know the money, report suspicion silently, keep records.
Exam framing
Expect scenario items on CDD triggers, reporting, and CPD evidence.