AML (ANTI-MONEY LAUNDERING) COMPLIANCE CHECKLIST

Created by ChecklistGuro (https://checklistguro.com)


--- CLIENT IDENTIFICATION & VERIFICATION (CIP) ---
[ ] Client Full Legal Name
[ ] Date of Birth (YYYY-MM-DD)
[ ] Type of Identification Document (Passport, Driver's License, National ID Card, Other)
[ ] Upload Copy of Identification Document
[ ] Identification Document Number
[ ] Date of Identification Document Expiry (YYYY-MM-DD)
[ ] Residential Address Verification (utility bill, bank statement, etc. - describe verification method)
[ ] Client Type (Individual, Company, Trust, Other)

--- TRANSACTION MONITORING & REPORTING ---
[ ] Transaction Amount Threshold for Review
[ ] Red Flags Observed (Select all that apply) (Unusual Transaction Patterns, Inconsistent Information, Complex Ownership Structure, Cash-Intensive Transactions, Geographic Risk, Lack of Apparent Business Purpose)
[ ] Description of Suspicious Activity
[ ] Date of Suspicious Transaction
[ ] Transaction Type (Purchase, Sale, Rental, Refinancing, Other)
[ ] Number of Related Transactions within a defined period
[ ] Supporting Documentation (e.g., bank statements, contracts)

--- POLITICALLY EXPOSED PERSONS (PEP) SCREENING ---
[ ] PEP Status Determination (Clearly Not a PEP, Potentially a PEP - Further Investigation Required, Confirmed PEP)
[ ] Reason for PEP Determination
[ ] PEP's Name (if applicable)
[ ] PEP's Position (if applicable)
[ ] Date PEP Status Determined
[ ] Enhanced Due Diligence (EDD) Actions Taken
[ ] Level of Enhanced Due Diligence Applied (Standard EDD, Moderate EDD, High EDD)
[ ] Supporting Documentation (e.g., news articles, official publications)
[ ] Name of Person Responsible for PEP Determination

--- RECORD KEEPING & DOCUMENTATION ---
[ ] Client Onboarding Date
[ ] Client Identification Documentation Review Notes
[ ] Copies of Client Identification Documents (Passport, Driver's License, etc.)
[ ] Summary of Beneficial Ownership Information
[ ] Supporting Documents for Beneficial Ownership Verification
[ ] Transaction Reference Number
[ ] Suspicious Activity Report (SAR) Filing Notes (If Applicable)
[ ] Date of Last Review of Client File
[ ] File Retention Status (Active, Archived, Destroyed (with justification))

--- TRAINING & AWARENESS ---
[ ] AML Training Modules Completed (Select all that apply) (Client Identification & Verification, Transaction Monitoring, PEP Identification, Sanctions Screening, Real Estate Specific Risks, Record Keeping Requirements)
[ ] Date of Last AML Training
[ ] Frequency of Refresher Training (Months)
[ ] Summary of Training Content Delivered
[ ] Training Delivery Method (Online Module, In-Person Workshop, Combination of Both)
[ ] Employee Name (Training Record)
[ ] Assessment Score (Post-Training) (Excellent, Satisfactory, Needs Improvement)
[ ] Proof of Training Completion (Certificate/Record)

--- RISK ASSESSMENT & MITIGATION ---
[ ] Describe the methodology used for the AML Risk Assessment.
[ ] Frequency (in months) of Risk Assessment Review.
[ ] Risk Level Designation (High, Medium, Low) (High, Medium, Low)
[ ] Identify key AML risks specific to your real estate business (select all that apply). (Shell Company Usage, Cash Transactions, Offshore Transactions, Property Flipping, Complex Ownership Structures, Third-Party Payments)
[ ] Describe mitigation strategies implemented for each identified risk.
[ ] Upload a copy of the documented Risk Assessment.
[ ] Date of last Risk Assessment Review

--- SANCTIONS SCREENING ---
[ ] Sanctions Screening Method (Automated Screening Software, Manual Screening (against a list))
[ ] Client Name (for Screening)
[ ] Client Address (for Screening)
[ ] Client Identification Number (e.g., TIN, Passport Number)
[ ] Date of Screening
[ ] Screening Results & Notes (e.g., matches found, discrepancies, investigation steps)
[ ] Screening Outcome (No Match, Potential Match - Requires Further Investigation, Confirmed Match - Transaction Blocked, Confirmed Match - Transaction Permitted (with enhanced due diligence))
[ ] Supporting Documentation (e.g., screenshot of screening software results)

--- DUE DILIGENCE ON THIRD PARTIES ---
[ ] Third Party Type (Agent, Broker, Property Manager, Legal Counsel, Other (Specify))
[ ] Third Party Name
[ ] Description of Services Provided
[ ] Copy of Third Party Identification Documents (e.g., Passport, Driver's License)
[ ] Beneficial Ownership Verification (if applicable) (Verified - Beneficial Owner(s) Identified, Not Applicable - No Beneficial Owners, Verification Pending)
[ ] Notes on Due Diligence Performed (e.g., background checks, sanctions screening)
[ ] Due Diligence Completion Date
[ ] Sanctions Screening Performed? (Yes, No)
[ ] If Sanctions Screening Performed, Sanctions Screening ID

--- REAL ESTATE SPECIFIC RISKS ---
[ ] Is a Risk Assessment conducted specifically for Real Estate transactions? (Yes, No, N/A)
[ ] Describe processes for identifying and mitigating risks associated with shell companies utilized in property transactions.
[ ] Maximum acceptable value of cash transactions (threshold definition and justification)
[ ] Which common layering techniques are addressed in training materials? (Multiple Property Purchases, Rapid Property Flipping, Use of Multiple Legal Entities, Complex Mortgage Structures, Offshore Accounts Involved)
[ ] Describe procedures for verifying the source of funds for large cash deposits used for property purchases.
[ ] Are valuations independently reviewed before property transactions? (Yes, No, N/A)
[ ] Date of last review of Real Estate specific risk assessment

--- COMPLIANCE PROGRAM REVIEW & UPDATES ---
[ ] Last Program Review Date
[ ] Summary of Review Findings
[ ] Areas of Program Updated (Select all that apply) (Client Identification Procedures, Transaction Monitoring Rules, Risk Assessment Methodology, Employee Training Materials, Internal Policies & Procedures, Reporting Thresholds, Sanctions Screening Processes)
[ ] Frequency of Program Reviews (e.g., Annually, Bi-Annually)
[ ] Rationale for Changes Made (Explain why changes were implemented)
[ ] Updated Risk Assessment Document
[ ] Next Review Trigger (What event will prompt the next review?) (Anniversary Date, Regulatory Change, Significant Change in Business Activity, Internal Audit Findings)
[ ] Date of Next Scheduled Review

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