RES exam question on AML / CFT: A buyer pays a deposit in several cash tranches, each kept just under a level he…
Case study — A buyer pays a deposit in several cash tranches, each kept just under a level he believes attracts scrutiny. The ownership behind the buyer is opaque. The agency is handling the transaction. Evaluate the statements: (i) Splitting payments to evade detection ('structuring') is a recognised red flag (ii) The agency must still perform customer due diligence (iii) A Suspicious Transaction Report may be warranted (iv) The involvement of a conveyancing lawyer removes the agency's AML duties Which statements are CORRECT?
- A(i), (iii) and (iv) only
- B(i), (ii) and (iii) only
- C(i), (ii), (iii) and (iv)
- D(ii) and (iii) only
Show answer & explanation
Answer
B. (i), (ii) and (iii) only
Explanation
(i) is correct: splitting payments into sums kept below scrutiny thresholds ('structuring') is a recognised red flag. (ii) is right because the agency must still perform customer due diligence, especially given the opaque ownership. (iii) holds because a Suspicious Transaction Report may be warranted.
Why the other options are wrong
- (iv) is false and the trap: involving a conveyancing lawyer does not remove the agency's own AML duties, which apply independently to the agency.
Study the concept behind this question: AML/CFT for Property Agents: CDD, Source of Funds & STR
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