• Conveyancers

    Some services provided by the conveyancers are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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What are the ML/TF Risks?

Conveyancers provide certain services that operate as a gateway to property and financial markets, financial institutions and other regulated professionals.

These ‘gatekeepers’ provide financial services that can be abused to disguise beneficial ownership, conceal the origins and purposes of financial transactions, facilitate tax evasion and, ultimately, launder the proceeds of crime.

The Money Laundering and Terrorism Financing (ML/TF) risks associated with conveyancing include:

  • Operating through or behind a professional adviser can provide a veneer of legitimacy to criminal activity;
  • Conveyancers can facilitate a process that allows for the transfer of ownership of property, a high-value asset that provides ideal opportunities for laundering large volumes of illicit funds;
  • Transactions may involve a disproportionate amount of private funding/cash, which is inconsistent with the profile of the purchaser;
  • Transactions may be unusual because of the manner of execution;
  • Funding or involvement of third parties without apparent connection or legitimate explanation;
  • Request to act for multiple parties without meeting them;
  • Transactions being inconsistent with the age and profile of the parties; and
  • Clients may provide false of counterfeited documentation to confirm their identity.

Conveyancers must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/ CFT laws.

What are the AML/CFT obligations?

In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:

  • Conduct a Money Laundering and Terrorism Financing Risk Assessment;
  • Develop an AML Program that is proportionate to ML/TF Risks;
  • Establish effective Board and Senior Management oversight of the AML/CFT Program;
  • Appoint an AML Compliance Officer;
  • Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
  • Implement a ML/TF Risk Awareness Training Program for staff;
  • Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
  • Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
  • Establish Record-keeping controls; and
  • Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for the conveyancing industry.

Our solutions deliver all the foundational AML/CFT materials including a ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.

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