2. 2 The Money Laundering Reporting Officer a . Since you are presently studying to become a non-principal estate agent your principal has decided to appoint you as the MLRO for your estate agency enterprise. Explain to your principal the role and functions that you will now have to undertake and give her specific examples of what you intend to do as the MLRO of the enterprise. 1. Make sure that the accountable institution meets its obligations in terms of FICA 2. Receive and consider internal disclosure of suspected money laundering or terrorists financing 3. Decide whether there are sufficient grounds for suspicion to pass the disclosure to SOCA 4. File a suspicious activity with SOCA where the grounds for suspicion are sufficient 5. Organise and arrange anti-money laundering training of the firms staff. 5 2. 3 “Know your client” Your principal has been asked to address a seminar on the identification and verification procedures that are contained in FICA. He instructs you to conduct the research and prepare the flash cards he will need to deliver his presentation. You must make specific reference to :- a The categories of clients indicated in the money laundering legislation 1 Attorneys 2 Estate agents 3 Banks and other financial institutions 4 Casinos 5 Life insurances companies b The documents required to identify and very each category of client 1 INDIVIDUALS -ID document -Proof of residence -Signed Mandate 2. TRUSTS - Trust deed - Id documents of the representative 3. CLOSE CORPORATION - Id documents of the representative - Founding statement certificate of Registration (CK1) - Amended founding statements (CK2) 4. PARTNERSHIP - ID 1 0
- Proof of residence - Signed mandate 5. PRIVATE COMPANIES - Certificate of incorporation - List of directors - ID and proof of residence of all directors 2. 4 Record keeping documentation and time frames a . b . Scenario You have been appointed as the MLRO of your estate agency firm. In this capacity you are required to: Draft a memo in which you discuss the requirements relating to the accessibility of information and; You have to keep up an audit trail so that any criminal funds which may pass through your firm and through your financial structure can be easily linked to the original crime or source such as: - Legal requirements - Anti-money laundering policies and procedures - Reasonable period - Internal and external reports - To track all the clients records - Identify and verification of all the records Provide your principal with a list of the different records that the firm must keep as well as statutory time frames for record keeping.
You've reached the end of your free preview.
Want to read all 5 pages?
- Winter '15
- Estate agent, National Association of Estate Agents, estate agency