AML update and reminders

Department of Internal Affairs (DIA) website updates

In March 2019, DIA issued its latest AML/CFT news update here(external link).

The issue includes useful information on suspicious activity reports(external link) and a new section of their website specifically for real estate agents.(external link)

New goAML (live) environment

Submitting suspicious activity reports (SARs) is an important AML/CFT measure for detecting money laundering and terrorism financing. They are submitted by a reporting entity through goAML(external link) when activity is observed that raises red flags and gives reasonable grounds for suspicion. Submission of a SAR is anonymous and confidential.

There is no requirement to stop acting for a client if you suspect suspicious activity but you must complete your SAR obligations. It is important to understand that the AML legislation overrides the Real Estate Agents Act 2008 and your fiduciary obligation to your vendor. If you cannot complete the consumer due diligence on the client, you cannot enter into a business relationship with them.

A reminder that your first annual report is due to the DIA by the end of August for the period 1 January - 30 June 19, read more here(external link).

Upcoming training events

The DIA is hosting a series of training events to help businesses identify what they need to do to complete a risk assessment and document an AML/CFT programme.

Workshops are from 11 June to 3 July around the country - find out more here(external link).