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by a client who wants to buy several high-value properties using physical cash payments of just under $10,000 each, withdrawn from different bank accounts.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.
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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.)