CEA explains AML compliance expectations for property agents
CEA clarified industry implementation of anti-money-laundering and related requirements.
What happened?
CEA's April 2026 guidance discusses amended AML, counter-proliferation financing and counter-terrorism financing requirements that took effect on 1 July 2025. The publication date of guidance is not the legal commencement date.
Why this matters for the RES exam
Practical exam scenario
An agent receives incomplete customer due diligence information. The agent should follow applicable verification, risk assessment, escalation and recordkeeping requirements, not treat the deal as exempt.
Worked decision: what should an agent do with incomplete due diligence?
Separate three issues: the publication date of CEA guidance, the commencement date of the underlying requirements, and the information required for the particular transaction. The 2026 guidance does not mean that duties only began in 2026. If due diligence information is incomplete, the agent should follow the applicable verification and escalation procedures rather than assume the transaction is exempt.
Common RES exam trap: Exam trap: memorising the guidance publication date as the legal effective date, or treating a missing document as a reason to skip risk assessment.
Related RES learning
3.1 Regulation of Real Estate Agency Industry
Official reference
Read the official government publication ↗
Test Your Understanding
Question: CEA published AML guidance in April 2026. When did the underlying amended requirements take effect?
Show answer and explanation
Correct answer: A. The guidance was published in 2026 but explains requirements effective from 1 July 2025.