CDD-Guide-A-risk-based-Approach.pdf

Here is a summary of the document in English, highlighting only the key points:

Purpose: The document provides guidelines for real estate brokers/developers/agents on how to perform Customer Due Diligence (CDD) as part of their anti-money laundering and counter-terrorism financing efforts.

Key Points:

1. Risk-Based Approach: DNFBPs (designated non-financial businesses and professions) should take a risk-based approach to CDD, considering factors such as the type of customer, products/services, geographic areas, and delivery channels.
2. High-Risk Scenarios: Identify high-risk scenarios that may indicate money laundering or terrorism financing, including:
   • Links to negative news or crime
   • Unusual payment methods or cash transactions
   • Lack of transparency in business activities or property purchases
3. Mitigating Risks: Implement adequate policies and procedures to mitigate identified risks, ensuring they are proportionate to the risk levels.
4. Red Flags: Be aware of red flags that may indicate money laundering or terrorism financing, such as:
   • Cash-intensive transactions
   • Unusual payment methods or large cash deposits
   • Lack of transparency in business activities or property purchases
5. Gut Instinct: Trust your instincts when performing CDD and be guided by the law, but also listen to your gut feeling if something seems suspicious.
6. Collaboration: Remind all brokers/developers/agents that they are part of a collective effort to protect their industry, jobs, and country from money laundering and terrorism financing.

By following these guidelines and being aware of high-risk scenarios and red flags, real estate professionals can effectively perform CDD and contribute to the fight against financial crime.