This short guidance is intended to provide AML/CFT obligations of Real Estate Agents at a glance and is put out only for informational purposes. The binding legislative and regulatory obligations are provided in the Anti-Money Laundering (AML) Act, 2010 and FBR AML/CFT regulations for DNFBPs, 2020.
IDENTIFICATION AND VERIFICATION OF CUSTOMER
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VERIFICATION OF SOURCE AND ORIGIN OR RECEIPTS AND PAYMENTS | COMPLIANCE PROGRAM AND PROMPT REPORTING | RISK PROFILING |
· Politically exposed person-PEP
· Enhanced due diligence · Ongoing process · Design customers form in compliance of AML laws · |
a. Source Verification
b. Origin Verification of the Amount c. Payment Type Verification |
1) Suspicion transaction reporting to FMU
2) Appoint independent Compliance Officer to report the non-compliance to company’s owners on regular basis 3) Use data analytics to identify the suspicious transactions 4) Collaborate and stay in touch with authorities 5) Stay updated with the new laws and regulations and red flags related to AML compliance 6) Independent Audit Function 7) CTR of Cash 2 million or above 8) Don’t Disclose to Customer
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· AML / CFT policy, procedures, and controls SOP
· Develop policies and procedures to bring uniformity and enhanced the importance of the AML compliance · Conduct training of the employees · Design and develop your ERP in a way to control the customers identification and transactions · Retain the record for 5 Years · High Risk / Customers and Transactions More Controls More Measures · Risk Wise Customers Category PEP, Location Wise, Nature of Business, Adverse Media Coverage, Mode of Transactions, NGO etc.
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