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RES exam question on AML / CFT: Salesperson Terence collected his buyer client's NRIC copy and source-of-funds documents…

MediumAnti-Money Laundering (PMLPFTF) · Paper 2

Salesperson Terence collected his buyer client's NRIC copy and source-of-funds documents on his own phone. The purchase completed in June 2026. His agency's compliance officer is setting out what happens to those records now. Which of the following statements is/are correct? (i) Terence may keep his own copies on his phone as a backup for the full retention period. (ii) The records are to be kept as paper originals, electronic copies not being accepted. (iii) Terence submits the documents he obtained to his estate agent, which keeps the records. (iv) The records may be destroyed now, since the transaction has closed.

  1. A(i) and (iii) only
  2. B(iii) only
  3. C(ii) and (iii) only
  4. D(i) and (iv) only
Show answer & explanation

Answer

B. (iii) only

Explanation

Answer: (iii) only. The agency keeps the records, in paper or electronic form, for at least 5 years from completion of the work.(iii) True. The record-keeping duty is the agency's, so he submits what he obtains and deletes copies from his own devices.Rule: The estate agent keeps due diligence records for at least 5 years after the estate agency work is completed, in original or copy form, including electronically. Salespersons submit what they obtain to the agency.Source: Estate Agents (Prevention of Money Laundering, Proliferation Financing and Terrorism Financing) Regulations 2021, as amended with effect from 1 July 2025; CEA, 'Preventing money laundering, proliferation financing, and terrorism financing' (cea.gov.sg, read 1 October 2026); CEA's FAQs on Estate Agents PMLPFTF Requirements (29 December 2025)

Why the other options are wrong

  • (i) False. Copies on a salesperson's phone are not the agency's record and are not kept securely, which also engages the PDPA protection obligation.
  • (ii) False. Electronic copies are accepted.
  • (iv) False. Completion starts the 5-year period rather than ending it.

Study the concept behind this question: AML/CFT for Property Agents: CDD, Source of Funds & STR

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