1. Conducting Due Diligence Checks on Customers and Unrepresented Counterparties
As part of customer due diligence (CDD) measures, RESs/EAs must assess the risk of ML/PF/TF when you conduct property transactions for your clients. This involves verifying the identity of the client and beneficial owner, identifying risk factors such as nature and purpose of the transaction; and for higher risk transactions, to establish the source of wealth or source of funds of your client and the beneficial owner.
2. Where the counterparty is not represented by an EA/RES, EAs and RESs must conduct Unrepresented Counterparty Due Diligence (UCPDD)
on the unrepresented counterparty (UCP) before their client enters into any agreement for the acquisition or disposition of property. This requirement applies to all rental, sale and purchase property transactions, with the exception of HDB residential rental transactions. Both CDD and UCPDD may be performed concurrently while preparing transaction-related paperwork.
3.EAs and RESs must screen clients, BOs, and UCPs against:
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FATF's "Black and Grey" lists
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Any lists provided by authorities
RESs and EAs are encouraged to subscribe to commercial AML/CPF/CFT screening solutions,
which provide comprehensive databases, real-time screening capabilities and specifically designed for the real estate industry's compliance needs.
RESs who screen their clients/UCPs manually can take screenshots of the screening results with date/time-stamps as evidence of relevant screenings having been conducted. RESs must submit all relevant information and supporting documents obtained during the conduct of CDD/UCPDD measures to their EAs.
If RESs/ EAs suspect that you are dealing with designated individuals or entities in the UN Sanctions List of the First Schedule of TSOFA, you must file a Suspicious Transaction Report (STR), and cease any dealing for the client in the property transaction, unless the client or UCP has obtained an Exemption Order under the TSOFA.
To help RESs/ EAs comply with the required CDD and UCPDD measures, CEA has provided sample checklists in the Guide on Estate Agents (Prevention of Money Laundering, Proliferation Financing and Financing of Terrorism) Regulations 2021 (PDF, 803KB) to provide a step-by-step guide for RESs/ EAs to conduct CDD and UCPDD checks.
4. Filled up the necessary AML Forms and keep a record.
If you have further questions about CDD requirements, you may refer to CEA’s Preventing Money Laundering and Financing of Terrorism webpage, or write to us at Inspection@cea.gov.sg for clarification.
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Submit New transaction
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Use this form to submit to CEA
1st step : save this form
2nd step : fill up the form
3rd step : fill up the E-submission below and attached the CEA Form
