The FIC has just released its March 2022 Assessment of the inherent money laundering and terrorist financing risks: REAL ESTATE SECTOR.
We suggest that you read the report in full. Some core findings are:
- Some 6910 cash threshold reports were made to the FIC since 2016. Clearly people still use cash in excess of R25 000 to make deposits and other payments to estate agents. Oddly, only 95 reports of suspicious transactions were received in this time.
- At par 6.1.3 onwards, the FIC states that:
- method of payment; and
- deal value
could be triggers to identify money laundering. Keep watch of these in your transactions. Also refer to par 6.2 where the FIC highlights that complex ownership structures may point to untoward dealings requiring your oversight.
- Further, from 6.2.2 to 6.3.3, potential warning lights are identified.
It may be necessary for you to update your RMCP (Risk Management and Compliance Program) in light of the content of the report.
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