A real estate agent is approached by a client who wants to buy several high-value properties using physical cash payments of just under $10,000 each, withdrawn from different bank accounts. The client refuses to provide identification beyond the minimum required. What is the most appropriate response under AML/CTF obligations?
Correct Answer
B) Lodge a suspicious matter report and consider declining the transactions
This pattern suggests 'structuring' or 'smurfing' - deliberately breaking large amounts into smaller transactions to avoid reporting thresholds. This requires filing an SMR and potentially refusing the transactions.
Why This Is the Correct Answer
Payments deliberately kept under the $10,000 threshold, combined with reluctance to provide identification, point to structuring. The agent should lodge a suspicious matter report and may decide not to proceed, without tipping off the client.
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A real estate agent discovers that a client has provided false identification documents during a property transaction. What is the most appropriate immediate action?
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At general law, an agent who proposes to act for both the vendor and the buyer in the same sale must at least do what? (Some states' conduct rules restrict this further.)