AML/CFT Training for Real Estate Professionals: Building a Culture of Compliance
AML/CFT Training for Real Estate Professionals: Building a Culture of Compliance
AML UAE conducted AML training programs designed to elevate compliance standards for a prominent UAE-based real estate company.
Our client, a leading real estate entity in the UAE, faced significant challenges in implementing effective Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) measures. With a large and diverse team, including real estate agents, compliance officers, and senior management, the company struggled with timely compliance and understanding of AML regulations.
Customer Goals:
To address the need and requirements of AML compliance, our client had the following objectives that made it approach AML UAE to undertake the AML training program:
- Increase AML awareness and best practices across all employee levels to identify, prevent, detect, and report suspicious transactions.
- Equip employees with fundamental AML/CFT concepts and their importance to support and oversee compliance efforts.
- Empower professionals and managers to ensure robust AML/CFT compliance and nurture a culture of compliance.
- Provide advanced training for the Compliance Officer/Money Laundering Reporting Officer (MLRO) to combat financial crime effectively.
Challenges:
Given the size of the team and the nature of the operations, the client faced challenges in adopting comprehensive and effective AML/CFT/CPF measures.
- Lack of awareness – Employees were not fully aware of their AML obligations, leading to inadequate compliance.
- Staff turnover – Frequent changes in staff and un-avoided employee turnover delayed compliance efforts.
- Complex transactions – Real estate transactions involve multiple parties and complex financial arrangements, making it challenging to detect suspicious activity.
Therefore, these challenges underscored the need for a tailored, comprehensive AML/CFT training program to address both general and industry-specific issues.
Legal Background:
The real estate professionals were governed by:
- Federal Decree Law No (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations
- Federal Decree Law No (26) of 2021 to amend certain provisions of Federal Decree Law No (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations
- Cabinet Decision No (10) of 2019 concerning the Executive Regulations of Federal Decree Law No (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations
- Guidelines for Designated Non-Financial Businesses and Professions (DNFBPs)
- Supplemental Guidance for the Real Estate Sector issued by the Ministry of Economy
The AML/CFT framework in the UAE includes real estate entities and professionals within the list of Designated Non-Financial Businesses and Professions (DNFBPs). As a DNFBP, the client was required to adhere to stringent AML regulations to combat financial crimes effectively.
For this purpose and to combat ML/FT crimes, they need to implement robust measures, which include equipping staff with AML compliance requirements through training programs.
Solution Provided by AML UAE Team:
AML UAE crafted and delivered a comprehensive training and awareness program tailored to the real estate sector.
The overall approach of the training program was designed to address the unique needs of the client and equip staff with the knowledge to identify, detect, and respond to ML/FT activities, including red flags and the importance of reporting suspicious transactions promptly.
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Employees Group |
Challenge Faced |
Solution-oriented AML Training Program |
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Real estate agents and brokers |
– Lacked knowledge of AML compliance regarding the Real Estate sector
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– Acquired the basic session to introduce ML/FT/PF risk and governing laws in UAE. |
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– Not able to identify red flags indicating ML/FT or PF instances in the Real Estate sector
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– Discussed and established an understanding of ML/FT and PF related red flags and common ML/FT/PF typologies pertaining to the Real Estate sector and needs. |
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– Faced resistance from customers in obtaining information
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– Helped them to apply techniques and strategies for effective communication and addressing customer concerns. |
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AML Compliance team |
– Adapting to regulatory changes
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– Helped them update their AML compliance requirement and aligned them with the latest AML regulations, guidelines, and industry best practices.
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– Lack of support from customers in providing KYC data
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– Emphasised the importance of coordinating with customers and communicating effectively about legal obligations. |
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– Difficulty in handling complex cases |
– Offered advanced training on analysing and addressing complex cases and emerging trends indicating ML/FT or PF activities. |
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Senior Management |
– Drafting effective AML policy and implementation
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– Guided in developing and refining AML policies and ensuring they align with regulatory requirements and best practices. |
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– Balancing compliance and employees' interest
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– Helped to establish a culture of compliance throughout the organisation and engage employees at all levels. |
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– Employee Turnover
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– Provided recorded training sessions.
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Compliance officer |
– Implementing ML/FT and PF risk assessment technique |
– Tailored the training program for advanced compliance monitoring techniques and risk assessment methodologies. |
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– Compliance crisis management |
– Aided in preparing strategies for managing potential ML/FT and PF related crises and regulatory investigations. |
The training was delivered in virtual mode by CAMS-certified AML Experts to ensure the flexibility and effectiveness of the AML Training Program.
Additionally, based on training, AML UAE also conducted tests to analyse the level of understanding of the staff. Furthermore, all participants were provided with a certificate of completion of the AML training.
AML UAE also provided the Real Estate entity with recordings of AML training sessions, adding value to the client.
End Result:
Through collaboration with the AML UAE team, the client experienced a significant improvement in its overall efficiency in undertaking AML measures, leading to enhanced compliance with AML regulations and mitigating the risk of regulatory fines and penalties.
As a result of this successful collaboration, the real estate entity experienced a 45% reduction in compliance-related issues.
Further, with the tailored training program focusing on how to approach customers, real estate agents and professionals saw a 65% increase in effective customer onboarding and streamlined the collection of critical documents, facilitating the compliance team’s ability to meet AML requirements more efficiently.
The client was able to take the proactive approach to AML compliance with well-trained staff, who were empowered to play an active role in preventing financial crime and upholding integrity and professionalism.
Through this successful collaboration, the real estate firm navigated complex regulatory landscapes effectively and established a strong culture of compliance, demonstrating its dedication to upholding the highest standards in the industry.
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