AML (Anti-Money Laundering) Compliance Checklist
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Client Identification & Verification (CIP)
Ensuring accurate and thorough identification and verification of all clients and beneficial owners.
Client Full Legal Name
Date of Birth (YYYY-MM-DD)
Type of Identification Document
Upload Copy of Identification Document
Identification Document Number
Date of Identification Document Expiry (YYYY-MM-DD)
Residential Address Verification (utility bill, bank statement, etc. - describe verification method)
Client Type
Transaction Monitoring & Reporting
Establishing procedures to monitor transactions for suspicious activity and reporting them to the relevant authorities.
Transaction Amount Threshold for Review
Red Flags Observed (Select all that apply)
Description of Suspicious Activity
Date of Suspicious Transaction
Transaction Type
Number of Related Transactions within a defined period
Supporting Documentation (e.g., bank statements, contracts)
Politically Exposed Persons (PEP) Screening
Identifying and verifying Politically Exposed Persons (PEPs) and their connections.
PEP Status Determination
Reason for PEP Determination
PEP's Name (if applicable)
PEP's Position (if applicable)
Date PEP Status Determined
Enhanced Due Diligence (EDD) Actions Taken
Level of Enhanced Due Diligence Applied
Supporting Documentation (e.g., news articles, official publications)
Name of Person Responsible for PEP Determination
Record Keeping & Documentation
Maintaining comprehensive and accurate records for all AML-related activities.
Client Onboarding Date
Client Identification Documentation Review Notes
Copies of Client Identification Documents (Passport, Driver's License, etc.)
Summary of Beneficial Ownership Information
Supporting Documents for Beneficial Ownership Verification
Transaction Reference Number
Suspicious Activity Report (SAR) Filing Notes (If Applicable)
Date of Last Review of Client File
File Retention Status
Training & Awareness
Providing regular AML training to employees and ensuring ongoing awareness of risks and responsibilities.
AML Training Modules Completed (Select all that apply)
Date of Last AML Training
Frequency of Refresher Training (Months)
Summary of Training Content Delivered
Training Delivery Method
Employee Name (Training Record)
Assessment Score (Post-Training)
Proof of Training Completion (Certificate/Record)
Risk Assessment & Mitigation
Conducting a comprehensive AML risk assessment and implementing controls to mitigate identified risks.
Describe the methodology used for the AML Risk Assessment.
Frequency (in months) of Risk Assessment Review.
Risk Level Designation (High, Medium, Low)
Identify key AML risks specific to your real estate business (select all that apply).
Describe mitigation strategies implemented for each identified risk.
Upload a copy of the documented Risk Assessment.
Date of last Risk Assessment Review
Sanctions Screening
Screening clients and transactions against sanctions lists to ensure compliance with relevant regulations.
Sanctions Screening Method
Client Name (for Screening)
Client Address (for Screening)
Client Identification Number (e.g., TIN, Passport Number)
Date of Screening
Screening Results & Notes (e.g., matches found, discrepancies, investigation steps)
Screening Outcome
Supporting Documentation (e.g., screenshot of screening software results)
Due Diligence on Third Parties
Implementing procedures for due diligence on agents, brokers, and other third-party intermediaries.
Third Party Type
Third Party Name
Description of Services Provided
Copy of Third Party Identification Documents (e.g., Passport, Driver's License)
Beneficial Ownership Verification (if applicable)
Notes on Due Diligence Performed (e.g., background checks, sanctions screening)
Due Diligence Completion Date
Sanctions Screening Performed?
If Sanctions Screening Performed, Sanctions Screening ID
Real Estate Specific Risks
Addressing AML risks unique to real estate transactions, such as layering, shell companies, and property flipping.
Is a Risk Assessment conducted specifically for Real Estate transactions?
Describe processes for identifying and mitigating risks associated with shell companies utilized in property transactions.
Maximum acceptable value of cash transactions (threshold definition and justification)
Which common layering techniques are addressed in training materials?
Describe procedures for verifying the source of funds for large cash deposits used for property purchases.
Are valuations independently reviewed before property transactions?
Date of last review of Real Estate specific risk assessment
Compliance Program Review & Updates
Regularly reviewing and updating the AML compliance program to reflect changes in regulations and emerging risks.
Last Program Review Date
Summary of Review Findings
Areas of Program Updated (Select all that apply)
Frequency of Program Reviews (e.g., Annually, Bi-Annually)
Rationale for Changes Made (Explain why changes were implemented)
Updated Risk Assessment Document
Next Review Trigger (What event will prompt the next review?)
Date of Next Scheduled Review
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