Q&As

Are there any CDD requirements for transferring money to an unrepresented third party in real estate transactions?

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Published on LexisPSL on 26/02/2016

The following Practice Compliance Q&A provides comprehensive and up to date legal information covering:

  • Are there any CDD requirements for transferring money to an unrepresented third party in real estate transactions?

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 came into force on 26 June 2017 and impose duties on firms including in relation to:

  1. training

  2. client due diligence (CDD) which includes ongoing monitoring

  3. record keeping, and

  4. designating a nominated officer

For more information, see Practice Note: Money Laundering Regulations 2017—systems and controls requirements—law firms.

CDD requirements (including source of funds) apply to your client and the beneficial owners of your client only. The MLR 2017 allow firms to take a risk-based approach to CDD and there is no specific requirement in the MLR 2017 to conduc

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