What action should a real estate agent take if they suspect a client is attempting to use their services for money laundering?
Correct Answer
D) Lodge a suspicious matter report with AUSTRAC without tipping off the client
When an agent suspects money laundering on reasonable grounds, the AML/CTF Act requires a suspicious matter report to AUSTRAC, and the agent must not tip off the client. The Act does not require the agent to refuse the transaction; whether to continue is a risk decision, though an agency cannot proceed if it cannot complete customer due diligence.
Why This Is the Correct Answer
Suspicion on reasonable grounds triggers a suspicious matter report to AUSTRAC, generally within three business days. The tipping-off prohibition bars telling the client. These are the two legal obligations; refusing the transaction is a separate risk decision rather than a requirement of the Act.
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