Navigating financial sanctions: OFSI sanctions guidance for high-value dealers and art market participants
The UK’s Office of Financial Sanctions Implementation (OFSI) has issued new guidance for high value dealers (HVDs) and art market …
Insight
With the launch of the 4th Anti-Money Laundering Directive came a little bit more clarity on guidance for Estate Agents.
The Government has now made it explicitly clear that both the vendor and the purchaser need to be checked. Section 6.3 of the consultation document states:
The government will clarify that for the purposes of the regulations, an estate agent is to be considered as entering into a business relationship with a purchaser as well with as a seller. This means that estate agency businesses must apply CDD to both contracting parties in a transaction.
The full Document can be found here.
I did say that the Government has provided a ‘little bit more clarity.’ What isn’t in the document is when Customer Due Diligence on the buyer should be carried out.
In reaching for an answer on how this will be interpreted in the Estate Agency sector we did a straw poll on how our clients will put this into practice and the clear majority are going to check purchasers at the point an offer is accepted.
Hardly scientific, but sooner than that would result in a waste of time and money, any later and it could be seen as a breach of the regulations.
