Governance & framework
Board and director responsibilities, appointment of the Compliance Officer, escalation paths and how the programme is reviewed and approved.
Policy & Procedures Pack
A complete AML/CFT framework — without the 200-page binder.
What's inside a Compliance1 policy pack: the six pillars every real estate agency needs, written in language your team will actually use.
Risk assessment
Customer, product, channel, geographic and institutional risk factors scored and documented — refreshed at least annually and on any material change.
Customer due diligence
Standard, simplified and enhanced CDD workflows, beneficial-ownership mapping, PEP and sanctions screening, source-of-funds and source-of-wealth procedures.
Ongoing monitoring
Trigger-based reviews, transaction monitoring expectations and how unusual activity is escalated, documented and (where required) reported.
Staff training
Role-based training for licensees, admin and senior managers — onboarding, annual refreshers, attendance records and assessment.
Record-keeping & reporting
What to keep, where and for how long. Annual report assistance and independent audit readiness baked into the workflow.
1. AML/CFT Framework
The framework sets out the agency's commitment to preventing money laundering and terrorism financing, defines the regulatory perimeter and explains how the Compliance Officer, principals and the wider team share responsibility. It also establishes how the programme connects to other risk and conduct policies.
2. Risk Assessment Steps
We follow a structured five-factor model (customer, product, channel, geographic, institutional), score each factor Low/Medium/High and document mitigations for everything above Low. Output is a one-page risk register backed by a detailed methodology paper — both versioned and signed off.
3. Customer Due Diligence
Procedures cover ID verification, beneficial ownership, PEP and sanctions screening, source of funds and source of wealth. Decision trees show licensees exactly when to escalate from standard to enhanced CDD without slowing legitimate deals.
4. Ongoing Monitoring
Procedures define trigger events, periodic review cycles, what 'unusual' looks like in property transactions, and how to escalate without tipping off. Every escalation is logged whether or not it becomes a report.
5. Staff Training
A training register tracks who has completed onboarding and annual refreshers, with assessment results. Materials cover red flags specific to residential and commercial property, role-based scenarios and the 'no tipping off' rule.
6. Record-keeping & Reporting
Defined retention periods, storage standards and access controls, plus templates for the annual report and audit evidence pack. Built so the next auditor can self-serve most of what they need.
Want this tailored to your agency?
We take this skeleton and shape it around your services, geography and team — not the other way around.
Start a compliance intakeFAQ
AML/CFT — Frequently asked questions
Quick answers to the questions we get most often from principals and licensees.
Compliance disclaimer
Content on this site is general information about AML/CFT obligations for real estate and does not constitute legal, regulatory or financial advice. Engage Compliance1 or qualified counsel for advice on your specific circumstances.Privacy
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