The use of real estate in ML/TF is well-known and demonstrable. FIU research indicates real estate is the ML asset of choice. In addition, this sector has low levels of AML/CFT awareness and sophistication. As such, this sector presents a medium-high inherent ML/TF risk.
The AML/CTF Act is activities-based and real estate agency work is one of the covered activities. Managing client funds (other than sums paid as fees for professional services), accounts, securities or other assets is another of the covered activities.
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