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New Anti-Money Laundering Requirements for Real Estate Agents and Lawyers

A Report by CYS Global Remit Legal & Compliance Office 

 

Overview 

In response to lessons from a major money laundering case involving billions of dollars, new anti-money laundering (AML) measures will be implemented in 2024 following recommendations from an inter-ministerial committee formed in late 2023.  

 

Key Requirements 

Client Identification and Verification 

  • Enhanced Due Diligence: Real estate agents and lawyers are required to conduct thorough client identification, especially focusing on individuals their clients may represent, ensuring comprehensive verification during property transactions. 

  • Beneficial Ownership Verification: Professionals must identify beneficial owners—those who benefit from the property without being official owners—to improve transparency in property ownership structures. 

 

Professional Sector Obligations 

For Real Estate Agents 

  • Client Monitoring: Identify and verify all unrepresented parties in transactions and continuously monitor existing clients to prevent misuse. 

  • Professional Inquiries: Conduct standard inquiries regarding the origin of funds, integrating them as a routine professional practice. 

For Legal Practitioners 

  • Enhanced Processes: Strengthen client identification and verification processes under customer due diligence requirements, aligned with the Legal Profession Act. 

  • Suspicious Activity Reporting: Fulfil additional obligations to report suspicious activities, supported by stringent record-keeping. 

 

Implementation Focus 

Regulatory Balance 

  • Business Consideration: The framework aims to balance legitimate business protection with strengthened AML measures. 

  • Asset Recovery: Highlighted focus on seizing illegal funds to effectively disrupt money laundering operations. 

 

Sector Support 

  • Education Initiative: Targeted education for non-regulated sectors, particularly high-value goods dealers, to enhance detection of potential money laundering activities. 

  • Monitoring Expansion: Increased focus on sectors like car dealerships and art dealing to raise awareness of money laundering risks. 

 

Framework Purpose 

These comprehensive reforms are a crucial part of Singapore's strategy to strengthen its financial security. They aim to seal regulatory loopholes and establish strong defenses against financial crimes, focusing on transparency in real estate transactions and high-risk sectors. These reforms are designed to support Singapore’s regulatory framework while maintaining its attractive business environment. By implementing these balanced changes, Singapore shows its commitment to financial and property sector integrity without compromising its appeal for legitimate business investments. 

These measures affirm Singapore's pledge to modernize its AML framework while fostering a secure environment for legitimate business activities. 

 

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