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RES exam question on Regulation & the CEA Framework: maximum financial penalty it may impose

HardRegulation of the Estate Agency Industry · Paper 2

CEA finds that salesperson Kenji failed to carry out customer due diligence on the buyers in three separate sales in 2026, worth $1.2 million, $980,000 and $2.1 million. There was no dishonesty and no loss to anyone, and CEA deals with the breaches through a Letter of Censure. What is the maximum financial penalty it may impose?

  1. A$5,000
  2. B$15,000
  3. C$100,000
  4. D$300,000
Show answer & explanation

Answer

B. $15,000

Explanation

Answer: $15,000. For anti-money laundering breaches the Letter of Censure cap is $5,000 per breach, and Kenji has three separate breaches.Working:1. 3 breaches × $5,000 = $15,000.Watch out: The sale prices are irrelevant.Rule: CEA may issue a Letter of Censure, with or without a financial penalty, for breaches with no or low financial loss, no or low wrongful gain and no dishonesty. The cap is $5,000 per case, but per breach for anti-money laundering, proliferation financing and terrorism financing breaches committed on or after 1 July 2025.Source: Estate Agents Act 2010, s 49(6) (sso.agc.gov.sg); CEA, Letter of Censure framework (cea.gov.sg, read 1 Oct 2026)

Why the other options are wrong

  • The per-case ceiling: $5,000 applies the per-case figure, not the per-breach rule for AML breaches.
  • A Disciplinary Committee's cap: $100,000 is a Disciplinary Committee's cap for a salesperson, not a Letter of Censure limit.
  • Committee cap multiplied by breaches: $300,000 applies that $100,000 per-breach cap to the three breaches.

Study the concept behind this question: Estate Agent Licensing vs Salesperson Registration (CEA)

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