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Scotland house prices end the year over 2 per cent higher

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Test your AML knowledge

Friday 21 June 2019

How well do you know the Anti-Money Laundering Regulations 2017? With the Fifth Anti-Money Laundering directive coming into force on 10 January 2020, are there any gaps in your knowledge and are you working within the law so far? You could face penalties of huge fines or even a prison sentence if you fail to comply.

The sheer size of the UK property market and the high value of property assets means that extremely large amounts of criminal funds can be ‘cleaned’ in a single transaction. The sales and lettings sectors, property auctioneers and high-value dealers are all attractive targets. Both small and large agencies are susceptible to criminal activity.

Make sure you understand the rules, educate yourself about the risks and ensure criminal gangs or unscrupulous individuals are not using your business to exploit their ill-gotten gains.

1) It is a criminal offence to trade as an estate agency business without being registered with HMRC for money laundering supervision

True

False

2) Which of the following could be an indication that your buyer/s may be involved in money laundering?

a) The buyer uses multiple bank accounts or foreign accounts without good reason

b) You’ve never met the buyer

c) The buyer is unusually anxious to complete the transaction and pushes for a quick without reason

d) All of the above

3) If you've noticed something suspicious who should you report it to in the first instance?

a) Your manager (or the business owner if you are a manager)

b) Your Money Laundering Reporting Officer (MLRO)

c) The business owner

d) The company’s solicitor

4) What should they then do with that information if they consider your suspicions are justified?

a) Pass it on to the police

b) Keep a written report and file safely away

c) Report to the company owner

d) Submit a report to the NCA

5) Who has a duty to report suspiciousactivity?

a) The most senior person in the company

b) Senior managers

c) All employees

6) NCA is an abbreviation for:

a) National Cartels Agency

b) Narcotics Crime Agency

c) National Crime Agency

7) What is a SAR?

a) Suspicious Activity Report

b) Sales Agency Register

c) Subject Access Report

8) The Money Laundering Directive is EU legislation which sets out the law, which EU countries, including the UK, must then bring into force via domestic legislation. What version of it are we now on?

a) Third Money Laundering Directive

b) Fourth Money Laundering Directive

c) Fifth Money Laundering Directive

9) New regulations are due to come into force by what date?

a) 1 April 2019

b) 10 January 2020

c) 31 March 2021

10) You must conduct Customer Due Diligence on:

a) Buyers

b) Sellers

c) Both buyers and sellers

11) In which of the instances given below should you conduct Enhanced Due Diligence?

a) On a politically exposed person

b) If the property is based in London

c) If you’ve never dealt with them before

12) You must keep records of Customer Due Diligence checks for…

a) 3 years

b) 5 years

c) 6 years

13) Which legislation introduced a new criminal offence of failing to prevent tax evasion?

a) Criminal Finances Act 2017

b) Proceeds of Crime Act 2002

c)  Terrorism Act 2000

14) What kind of businesses need to register with HMRC under the Money Laundering Regulations?

a) Estate Agents who regularly complete sales on property worth over £1 million

b) Commercial agents

c) All estate agents

15) Complete the following sentence: My business, or the business I work for offers lettings as well as sales, therefore …

a)  I only need to report suspicious activity for sales transactions

b) We don’t fall under the AML regulations

c) I must report suspicious activity for both sales and lettings side of the business

16) If you didn’t know for sure that your clients were actively involved in money laundering you can’t be prosecuted for money laundering offences.

True

False

17) What are the penalties for failing to comply with AML regulations?

a) Prison and/or an unlimited fine

b) A fine of up to £50,000

c) Community service and a fine of up to £5,000

d) Your business will go on a 'rogues' register, which could result in a loss of reputation

 

How do you think you did?

Answers

To help you comply

The NAEA Propertymark website has a dedicated page covering the ins and out of Anti-Money Laundering Regulations to assist you with complying.

NAEA Propertymark members can download the AML How to Comply Guide by logging into the Members Area.

AML training course - get up to speed by booking yourself on our foundation introductory online course, intermediate day course or advanced AML day course for MLROs. 

Workshops - NAEA Propertymark host free interactive workshops around the country to keep members up-to-date with changes in legislation. 

Webinar - Propertymark hosted An Introduction to Anti-Money Laundering webinar.

Other resources: