RES AML Guide 2027: PMLPFTF, CDD, Red Flags and STRs

RES AML Guide 2027: PMLPFTF, CDD, Red Flags and STRs Explained

A structured guide to the PMLPFTF framework within 2027 RES Topic 3.4, covering CDD, UCPDD, beneficial ownership, risk assessment, screening, PEPs, ECDD, source of funds and wealth, red flags, reporting, targeted financial sanctions and record obligations.

What Topic 3.4 covers and which rules are current

The revised Real Estate Salesperson examination syllabus applies to examinations from 1 January 2027. Within that syllabus, Topic 3.4 expressly includes Customer Due Diligence (CDD) and suspicious transaction reports (STRs). It also identifies the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act, the Terrorism (Suppression of Financing) Act and the United Nations Act 2001 among the applicable laws.[1][2]

Keep two dates separate. The principal 2025 PMLPFTF amendments came into operation on 1 July 2025. The revised RES syllabus applies to examinations from 1 January 2027. The later syllabus date does not mean the underlying 2025 amendments only begin in 2027.[1][3]

Use Topic 3.4 to understand the scope of what a 2027 candidate must study. For the substance of a duty, however, distinguish the syllabus from the regulation, statute or official guidance that creates or explains that duty. The syllabus defines the examination coverage; it should not be treated as though it were itself the operative legal rule.[2]

ML, PF and TF: core concepts and why real estate matters

Money laundering, proliferation financing and terrorism financing are related but distinct concepts.

Money laundering (ML) is described by CEA as the process of disguising proceeds of crime so that they appear legitimate. CEA describes placement, layering and integration as typical stages, with integration capable of involving apparently legitimate investments such as real estate.
Proliferation financing (PF) concerns providing funds connected with the spread of nuclear, chemical or biological weapons, their means of delivery and related materials.
Terrorism financing (TF) concerns providing funds for terrorist activities. CEA expressly notes that the funds may originate from legitimate or illegal sources, so terrorism financing is not limited to dealing with proceeds of crime.

[4]

CEA distinguishes the underlying threats from the measures used to counter them. ML, PF and TF mean money laundering, proliferation financing and terrorism financing. AML, CPF and CFT mean anti-money laundering, countering proliferation financing and countering the financing of terrorism. These countermeasures sit within the wider prevention of money laundering, proliferation financing and terrorism financing, or PMLPFTF, framework.[5]

CEA identifies characteristics of real estate that can create vulnerability to ML, PF and TF. These include large transaction values, complex ownership structures, the ability of property to generate apparently legitimate returns, and the potential use of properties for illicit activities or storage of illicit goods. EAs and RESs act as intermediaries in property transactions and are therefore positioned to identify suspicious clients or transactions, verify identities, detect unusual property-dealing patterns and report suspicious activities through the relevant process.[4]

Who must act: RES, estate agent and responsible person

The PMLPFTF Regulations use the term responsible person. The statutory definition identifies the registered salesperson and, in any other case, the licensed estate agent as possible responsible persons. This distinction matters because a rule should be attributed to the actor identified by that rule rather than treating every estate-agent-level and salesperson-level obligation as interchangeable.[6]

Where reliance on a third party is permitted, that reliance does not transfer the responsible person's compliance responsibility to the third party.[7]

The framework also contains a specific salesperson-to-estate-agent obligation. Regulation 15A requires a registered salesperson to submit specified documents and information to the licensed estate agent. The records section below deals with this obligation separately.[3]

The PMLPFTF decision model for property scenarios

A useful way to organise a property scenario is to move through the following questions.

Identify the party and representation status. Determine whether the relevant person is the RES's own client or an unrepresented counterparty.
Apply the relevant due-diligence branch. Ordinary CDD concerns the client, while CEA links UCPDD to the other party being unrepresented.
Separate the people involved. For an entity client, distinguish the entity from an individual acting for it and from the beneficial owner.
Check whether a trigger changes the measures required. Examples supported by the framework include Regulation 6 ECDD circumstances, targeted-financial-sanctions measures and rental-specific rules.
Where there is an ongoing business relationship, continue ongoing monitoring and periodic review of CDD information and documents.
Treat red flags as assessment inputs rather than automatic conclusions.
If a reporting threshold or another reporting duty is engaged, identify the correct rule and route rather than applying one generic reporting test.

[5][6][7][8][9][10][11][12][13][14][15][16]

Do not merge the reporting layers. CDSA section 45 provides a suspicion-based statutory threshold. TSOFA creates separate terrorism-related disclosure duties. CEA describes an RES operationally as filing an STR through the EA, while SPF identifies SONAR as the electronic channel for filing STRs to STRO.[5][15][16][17][18]

Customer Due Diligence: timing, identity and persons acting for clients

Regulation 4 makes timing and identity central to Customer Due Diligence. The required CDD must be completed before the relevant agreement, identity must be verified using reliable independent sources, and the responsible person must ascertain whether a person is acting on behalf of another person.[8]

These checks require the roles in a transaction to be kept separate. A corporate client is not the same person as its individual authorised signatory or contact person. Beneficial ownership is also a separate concept: a beneficial owner includes an individual who ultimately owns or controls an entity or legal arrangement.[9][10]

Corporate clients, authorised persons and beneficial owners

Where the client is, or is acting on behalf of, an entity or legal arrangement, Regulation 5 prescribes additional CDD measures. The responsible person must identify and verify the entity or legal arrangement, understand its nature and control structure, and perform the required beneficial-owner checks. The individual signatory or contact person should not simply be treated as though that individual were the corporate client.[9][19]

A beneficial owner includes an individual who ultimately owns or controls an entity or legal arrangement. Do not turn neighbouring percentage language into a universal beneficial-owner threshold.[10]

Fictional example: an RES acts for a company acquiring a property. The company is the client. A director who signs for the company is an individual acting for the client. An individual who ultimately owns or controls the company may be a beneficial owner. Those labels should not be collapsed into one person merely because the same individual could, in some cases, occupy more than one role.[9][10][19]

CDD versus UCPDD: representation status is the dividing line

CEA links Unrepresented Counterparty Due Diligence, or UCPDD, to the other party being unrepresented. Where both sides are represented in an ordinary co-broking transaction, each RES's CDD remains focused on that RES's own client. Co-broking itself does not create UCPDD.[5]

Representation status changes the due-diligence branch.

Represented buyer and represented seller: the buyer's RES focuses ordinary CDD on the buyer, and the seller's RES focuses ordinary CDD on the seller.
Represented buyer and unrepresented seller: the buyer remains the buyer RES's client for CDD, while the unrepresented status of the other party brings UCPDD into consideration.
Represented landlord and represented tenant: each RES remains focused on that RES's own represented client for ordinary CDD.
Represented landlord and unrepresented tenant: representation status changes the counterparty side of the analysis because the tenant is unrepresented.

[5]

Rental transactions: narrow exceptions and conditional low-risk variations

The current framework contains a specific exception for an HDB flat used wholly for residential purposes. It is not a general exemption for all rentals, all HDB property or all PMLPFTF obligations.[14]

For a non-exempt rental transaction, specified CDD measures may be varied only where both the client and the transaction are assessed as low risk. The counterparty-due-diligence regime contains a corresponding condition based on low risk in relation to both the unrepresented counterparty and the transaction. These are conditional low-risk variations, not blanket rental exemptions.[7][13][14][20]

Fictional comparison: if the transaction falls within the HDB-flat exception for a flat used wholly for residential purposes, apply that narrow exception. For another rental that is not exempt, do not assume reduced measures merely because it is a tenancy. Any variation depends on the specified low-risk conditions for the relevant person and the transaction.[7][13][14][20]

Risk assessment, screening, PEPs and when ECDD is triggered

CEA's risk-determination framework includes checks involving the person and the transaction. Considerations include whether a person is a foreign politically exposed person or connected person, whether red flags indicate higher transaction risk, whether a client or beneficial owner is from a FATF higher-risk or monitored jurisdiction, and whether the person matches terrorism-related or United Nations designation sources. These are categories for assessment, not an exhaustive universal taxonomy.[4]

Screening is therefore not a single-list exercise. CEA's framework includes checks for PEP status, FATF higher-risk and monitored jurisdictions, terrorist designations, United Nations sanctions or designated-person sources, and other lists provided by CEA or relevant authorities. Regulation 11 expressly includes a designated person as defined in regulations made under the United Nations Act 2001 within its targeted-financial-sanctions measures. Because the underlying lists can change, use current official sources rather than treating a list reproduced in a study guide as permanently current.[4][12]

Politically exposed person, or PEP, is broader than foreign PEP. The Regulations define PEP categories to include an individual entrusted with a prominent public function in Singapore, foreign PEPs, and persons entrusted with prominent functions by international organisations. Family members and close associates are separately defined connected-person categories. This broader definition should be distinguished from the narrower Regulation 6 trigger that expressly concerns a foreign PEP, or that foreign PEP's family member or close associate.[10][11][13]

Enhanced Customer Due Diligence, or ECDD, is not required for every client. Regulation 6 requires it where a Regulation 6(2) circumstance exists. The supported trigger set contains four circumstances:

The estate agency work presents a higher ML, PF or TF risk.
The relevant person is from or in a jurisdiction for which FATF has called for countermeasures or enhanced CDD.
The relevant person is a foreign PEP or a family member or close associate of a foreign PEP.
There is reason to suspect that the relevant person is engaged in ML, PF or TF.

[11]

When ECDD applies, it is additional to ordinary CDD. Regulation 6 requires designated-officer approval before establishing or continuing the business relationship, reasonable measures to establish both source of wealth and source of funds of the relevant person, and further reasonable measures appropriate to the ML, PF and TF risks. For the source-of-wealth and source-of-funds measure, the relevant person can be the client, the client's beneficial owner, a person on whose behalf the client acts, or that person's beneficial owner.[11]

A qualifying designated-person hit is not treated merely as another ordinary risk indicator. Where the applicable screening identifies a designated individual or entity and no relevant exemption applies, CEA's current framework requires the property dealing to stop and an STR to be filed.[5]

Source of funds versus source of wealth

Concept	Meaning	Key distinction
Source of funds	The particular funds or assets used for the transaction.	Transaction-funding-specific.
Source of wealth	The person's entire body of wealth.	Concerns overall wealth rather than only the assets used for one transaction.

[7]

When Regulation 6 ECDD applies, the responsible person must take reasonable measures to establish both source of wealth and source of funds of the relevant person. For this measure, the relevant person can be the client, the client's beneficial owner, a person on whose behalf the client acts, or that person's beneficial owner. The Regulation 6 proposition should not be treated as an exhaustive statement of every possible context in which source of funds or source of wealth might be relevant.[7][11]

Ongoing due diligence and third-party reliance

CEA guidance also states that ongoing due diligence cannot be delegated to third parties. Initial reliance and continuing monitoring are therefore distinct questions.[7]

Where there is an ongoing business relationship, the responsible person must conduct ongoing monitoring and periodically review the CDD information and documents. Keeping relevant information current forms part of that ongoing due-diligence obligation.[6]

Red flags are assessment inputs, not automatic conclusions

CEA's FAQ says that a single common red-flag indicator does not necessarily determine higher risk. A red flag is information to assess with the wider facts. By itself, it does not prove ML, PF or TF, determine a higher-risk classification or require an STR.[9]

CEA's checklist contains indicators across several supported areas.

Client, identity and beneficial ownership: examples include links to negative news or crime, multiple or unusual travel documents, shell companies unwilling to disclose beneficial owners, resistance to providing beneficial-owner or source-of-funds information, nominees or proxies, attempts to conceal beneficial ownership, inconsistent identity documents and suspicious addresses.
Transaction behaviour and structure: examples include rapid multiple purchases, unnecessarily complex legal structures and rapid property transfers.
Funding and payment: examples include disproportionate debt, large physical-cash payments, rent paid far in advance, unexplained third-party payments and purchases without financing.
Transaction economics: examples include apparent indifference to property characteristics, transaction values materially different from market value and unusual successive price changes.

[4]

For study purposes, keep three stages conceptually separate: spotting an indicator, assessing the facts and deciding whether a legal reporting threshold has been reached. Fictional scenarios can combine several supported indicators to practise that reasoning, but there is no supported basis here for assigning official numerical weights or claiming that a particular number of red flags automatically determines the result.[9][15]

What happens if required CDD cannot be completed

If a registered salesperson cannot or chooses not to complete required client CDD, Regulation 12 requires the transaction not to proceed and requires the registered salesperson to determine whether to file an STR. The second step is an STR decision. It should not be rewritten as a rule that every inability-to-complete case automatically requires an STR.[19]

For an unrepresented counterparty, Regulation 12H is a separate branch. Where required counterparty due diligence cannot be completed, or is not completed because the permitted tipping-off exception applies, the registered salesperson must not facilitate the entering into of the property agreement, must inform the licensed estate agent and must determine whether to file an STR. Regulation 12H also provides corresponding non-facilitation and STR-assessment duties for the licensed estate agent in the circumstances specified in Regulation 12H(3).[14]

The Regulation 12H(1) exception for choosing not to perform a counterparty due-diligence measure requires both conditions to be present: there must be reason to suspect that the unrepresented counterparty may be engaged in ML, PF or TF, and there must be reason to believe that performing the measure would tip off the unrepresented counterparty or another person.[14]

Suspicious transaction reporting: threshold, RES/EA route and SONAR

CDSA section 45 uses a knowledge-or-reasonable-grounds-to-suspect threshold and requires the disclosure to be made as soon as reasonably practicable. The threshold is suspicion-based rather than proof-based.[15]

Keep the operational route distinct from that statutory threshold. CEA's public wording tells an RES to file an STR through the EA. SPF identifies SONAR as the electronic channel for filing STRs to STRO. The through-the-EA step and the electronic filing channel describe different parts of the process and should not be confused with the substantive CDSA section 45 threshold.[5][15][17][18]

CEA distinguishes reporting from investigation. The role of an RES or EA is to identify and report qualifying suspicion through the prescribed process, not to establish whether a criminal offence actually occurred.[5][15]

CEA states that the identity of an STR filer is confidential and protected by law. Separately, CDSA section 57 contains a qualified tipping-off restriction. It applies to disclosures made with the specified knowledge or reasonable grounds for suspicion where the disclosure is likely to prejudice the relevant existing, proposed or possible resulting investigation. It should therefore not be reduced to a blanket rule that any discussion of an STR is prohibited.[5][15]

Terrorism-related disclosures and targeted financial sanctions

TSOFA creates terrorism-related disclosure duties that are distinct from the CDSA section 45 test. These include immediate notification concerning terrorist property and immediate disclosure of materially helpful terrorism-financing information. They should not be collapsed into the CDSA knowledge-or-reasonable-grounds-to-suspect threshold.[16]

Regulation 11's targeted-financial-sanctions measures expressly include a designated person as defined in regulations made under the United Nations Act 2001. CEA's screening framework also includes terrorist designations, designated individuals and entities and United Nations designated-person sources among its screening categories.[4][12]

Where applicable screening identifies a designated individual or entity and no relevant exemption applies, the consequence is to stop the property dealing and file an STR. This does not set out every possible freezing measure, dealing prohibition or other sanctions consequence.[5][12]

Record keeping and submission of due-diligence material

Regulation 14 requires specified records to be maintained for at least five years after the relevant estate agency work.[21]

Regulation 15A requires a registered salesperson to submit specified documents and information to the licensed estate agent. This article does not reproduce an exhaustive list of every record or document covered.[3][21]

Worked property scenarios: apply the decision model

The scenarios below are fictional ConfirmPass examples for practising rule application. They are not past RES questions, CEA questions or representations of actual examination wording.

Scenario 1, represented buyer and seller: Buyer B is represented by RES B and Seller S is represented by RES S. Both parties are represented. Each RES's ordinary CDD remains focused on that RES's own client. The fact that two RESs are co-broking does not itself create UCPDD. The first classification question is therefore representation status, not simply whether another salesperson is involved.[5]

Scenario 2, unrepresented counterparty: Buyer B is represented by RES B, while Seller S has no representative. Buyer B remains RES B's client. Seller S is the unrepresented counterparty. CEA links that unrepresented status to UCPDD, so the change from Scenario 1 is not the property itself but the representation status of the other party.[5]

Scenario 3, corporate client: RES C acts for Company C. Director D signs the transaction documents for Company C, while Individual O ultimately owns or controls Company C. Company C is the client, Director D is the individual acting for the company, and Individual O may be its beneficial owner. Regulation 5 requires additional entity or legal-arrangement measures, including identifying and verifying the entity, understanding its nature and control structure and carrying out the required beneficial-owner checks.[9][10]

Scenario 4, rental: first assume the tenancy falls within the exception for an HDB flat used wholly for residential purposes. Keep that exception narrow. Now change the facts so the rental is non-exempt. Any variation of specified CDD measures then depends on both the client and the transaction being assessed as low risk. For UCPDD, the corresponding rental condition concerns both the unrepresented counterparty and the transaction.[7][13][14][20]

Scenario 5, foreign PEP: a relevant person is identified as a foreign PEP. Regulation 6 expressly identifies a foreign PEP, and a foreign PEP's family member or close associate, as an ECDD trigger. Do not convert that rule into a claim that every PEP category automatically triggers ECDD in exactly the same way, because the broader PEP definition and the specific foreign-PEP trigger are distinct.[11]

Scenario 6, CDD cannot be completed: a registered salesperson cannot complete the required client CDD. Regulation 12 requires no transaction and requires the registered salesperson to determine whether to file an STR. The second requirement is a decision about whether reporting is required, not a rule that inability to complete CDD automatically means an STR must be filed.[19]

Scenario 7, red flags: a client provides inconsistent identity information and an unexplained third party proposes to make a payment. Both are suspicious indicators. Do not count the indicators and declare an automatic result. Consider them with the wider facts, assess the risk and then ask separately whether the CDSA knowledge-or-reasonable-grounds-to-suspect threshold has been reached.[4][9][15]

Scenario 8, terrorism-related information: facts arise concerning terrorist property or materially helpful terrorism-financing information. Do not force those facts into the CDSA section 45 framework alone. TSOFA creates distinct immediate disclosure duties for those terrorism-related circumstances, so the analysis starts by identifying which reporting rule is engaged.[16]

Master PMLPFTF obligation map

Concept or obligation	When it becomes relevant	Who must act	What must be done	Key distinction	Primary authority
Ordinary CDD	Before the relevant agreement where Regulation 4 CDD is required.	Responsible person.	Complete required CDD, verify identity from reliable independent sources and ascertain whether a person acts for another person.	ConfirmPass distinction: identify the client and acting-on-behalf relationship before moving to later risk questions.	PMLPFTF Regulations 2021, Regulation 4
Corporate or legal-arrangement CDD	Where the client is, or acts on behalf of, an entity or legal arrangement.	Responsible person.	Identify and verify the entity or arrangement, understand its nature and control structure and perform required beneficial-owner checks.	ConfirmPass distinction: the entity client, signatory and beneficial owner are separate roles.	PMLPFTF Regulations 2021, Regulation 5
Beneficial owner	Where ultimate ownership or control of an entity or legal arrangement must be identified.	Responsible person performing the applicable due diligence.	Apply the supported ultimate ownership or control concept.	ConfirmPass distinction: beneficial owner is not simply another name for the client or signatory.	PMLPFTF Regulations 2021, Regulation 2
UCPDD	Where the other party is unrepresented.	Relevant RES or responsible person under the counterparty-due-diligence regime.	Apply the supported counterparty-due-diligence requirements.	ConfirmPass distinction: representation status, not co-broking by itself, is the key dividing concept.	CEA PMLPFTF material
Co-broking with both parties represented	Where each side has its own RES.	Each RES.	Keep ordinary CDD focused on that RES's own client.	ConfirmPass distinction: co-broking does not automatically create UCPDD.	CEA public PMLPFTF material
HDB wholly-residential rental exception	Where the supported exception for an HDB flat used wholly for residential purposes applies.	Relevant responsible person.	Apply the specific exception only within its supported scope.	ConfirmPass distinction: do not generalise it to all rentals or all HDB property.	PMLPFTF Regulations 2021
Low-risk rental CDD variation	For a non-exempt rental where both the client and transaction are assessed low risk.	Responsible person.	Specified CDD measures may be varied under the supported rental rule.	ConfirmPass distinction: conditional low-risk treatment is not a blanket rental exemption.	PMLPFTF Regulations 2021, Regulation 7
Low-risk rental UCPDD variation	Where both the unrepresented counterparty and rental transaction meet the supported low-risk condition.	Responsible person under the counterparty regime.	Apply the corresponding conditional counterparty-due-diligence treatment.	ConfirmPass distinction: both the person and transaction conditions matter.	PMLPFTF Regulations 2021, Regulation 12E
Risk assessment	As part of the supported CDD risk-determination process.	EA or RES within the applicable framework.	Assess supported client or person and transaction risk indicators.	ConfirmPass distinction: risk indicators inform assessment rather than operating as automatic legal conclusions.	CEA PMLPFTF Guide
Screening	When the PMLPFTF framework requires applicable screening checks.	Relevant EA or RES.	Check supported categories including PEP status, FATF higher-risk or monitored jurisdictions, terrorist designations, United Nations designated-person sources and other applicable official lists.	ConfirmPass distinction: screening is a set of category-specific checks, not one permanent list.	CEA PMLPFTF Guide
PEP categories	When determining whether a person falls within a defined PEP or connected-person category.	Responsible person.	Distinguish Singapore PEPs, foreign PEPs and persons entrusted with prominent functions by international organisations, with family members and close associates separately defined.	ConfirmPass distinction: the overall PEP definition is broader than the foreign-PEP ECDD trigger.	PMLPFTF Regulations 2021, definitions
Regulation 6 ECDD trigger	Where estate agency work presents higher ML/PF/TF risk; the relevant person is from or in a FATF countermeasure or enhanced-CDD jurisdiction; the relevant person is a foreign PEP or connected category; or there is reason to suspect the relevant person is engaged in ML, PF or TF.	Responsible person.	Apply enhanced CDD in addition to ordinary CDD.	ConfirmPass distinction: ECDD is trigger-based and not universal.	PMLPFTF Regulations 2021, Regulation 6
ECDD approval and further measures	Once Regulation 6 ECDD is triggered.	Responsible person and designated officer for the supported approval step.	Obtain designated-officer approval before establishing or continuing the relationship and take further reasonable measures appropriate to the ML/PF/TF risks.	ConfirmPass distinction: these are enhanced measures added to ordinary CDD.	PMLPFTF Regulations 2021, Regulation 6
Source of funds	As a Regulation 6 ECDD measure when ECDD is triggered.	Responsible person.	Take reasonable measures to establish the particular funds or assets used for the transaction for the relevant person.	ConfirmPass distinction: source of funds concerns transaction funding, not the person's entire wealth.	PMLPFTF Regulations 2021, Regulation 6; CEA PMLPFTF Guide
Source of wealth	As a Regulation 6 ECDD measure when ECDD is triggered.	Responsible person.	Take reasonable measures to establish the relevant person's entire body of wealth.	ConfirmPass distinction: source of wealth and source of funds are not interchangeable.	PMLPFTF Regulations 2021, Regulation 6; CEA PMLPFTF Guide
Regulation 6 relevant person for source measures	When source of wealth and source of funds are required under Regulation 6.	Responsible person.	Apply the measures to the applicable client, client's beneficial owner, person on whose behalf the client acts, or that person's beneficial owner.	ConfirmPass distinction: do not assume the measure concerns only the named client.	PMLPFTF Regulations 2021, Regulation 6
Third-party reliance	Where permitted reliance on a third party is used for CDD.	Responsible person.	Retain compliance responsibility despite the reliance.	ConfirmPass distinction: reliance does not transfer regulatory responsibility.	CEA PMLPFTF Guide
Ongoing due diligence	Where there is an ongoing business relationship.	Responsible person.	Conduct ongoing monitoring and periodically review CDD information and documents.	ConfirmPass distinction: ongoing monitoring is separate from initial CDD reliance.	PMLPFTF Regulations 2021
Red-flag assessment	When suspicious indicators appear in the transaction facts.	EA or RES assessing the facts.	Consider the indicators with the wider circumstances.	ConfirmPass distinction: one red flag does not automatically prove ML/PF/TF, determine higher risk or require an STR.	CEA FAQs and PMLPFTF Guide
Unable to complete required client CDD	Where the registered salesperson cannot or chooses not to complete required client CDD.	Registered salesperson.	Do not proceed with the transaction and determine whether to file an STR.	ConfirmPass distinction: determining whether to file is not the same as an automatic STR in every case.	PMLPFTF Regulations 2021, Regulation 12
CDSA suspicious transaction reporting	Where the section 45 knowledge-or-reasonable-grounds-to-suspect threshold is reached.	Person subject to the statutory disclosure duty.	Make the required disclosure as soon as reasonably practicable.	ConfirmPass distinction: the threshold is suspicion-based rather than proof-based.	CDSA, section 45
RES operational STR route	Where an RES must file an STR under the applicable process.	RES through the EA.	Use the EA route described by CEA.	ConfirmPass distinction: the RES-through-EA route is operational and is separate from the statutory threshold.	CEA public PMLPFTF material
SONAR	When an STR is filed electronically to STRO.	Relevant filer.	Use SONAR as the electronic filing channel.	ConfirmPass distinction: SONAR is the channel, not the legal reporting threshold.	SPF Suspicious Transaction Reporting and SONAR material
TSOFA terrorism-related disclosures	Where the supported terrorist-property or materially helpful terrorism-financing information circumstances arise.	Person subject to the relevant TSOFA duty.	Make the applicable immediate notification or disclosure.	ConfirmPass distinction: TSOFA duties are distinct from CDSA section 45.	Terrorism (Suppression of Financing) Act 2002
Targeted-financial-sanctions designated persons	Where Regulation 11's supported designated-person measures apply.	Relevant responsible person.	Apply the targeted-financial-sanctions measures, including the supported United Nations Act designated-person category.	ConfirmPass distinction: use current applicable official designation sources rather than a frozen study list.	PMLPFTF Regulations 2021, Regulation 11
Applicable designated-person hit	Where screening identifies a designated individual or entity and no relevant exemption applies.	Relevant EA or RES under the current framework.	Stop the property dealing and file an STR.	ConfirmPass distinction: this supported consequence is stronger than merely treating the hit as an ordinary higher-risk indicator.	CEA public PMLPFTF material
Record retention	After completion of the relevant estate agency work.	Relevant person subject to Regulation 14.	Maintain specified records for at least five years.	ConfirmPass distinction: the evidence supports the retention period but not an exhaustive reproduction of every record.	PMLPFTF Regulations 2021, Regulation 14
RES submission to EA	Where Regulation 15A requires submission of specified due-diligence material.	Registered salesperson.	Submit the specified documents and information to the licensed estate agent.	ConfirmPass distinction: do not invent a complete document list where it is not supplied.	PMLPFTF Regulations 2021, Regulation 15A

[1][2][3][4][5][6][7][8][9][10][11][12][13][14][15][16][17][18][19][20][21]

FAQ for 2027 RES candidates

When does the 2027 syllabus take effect? The revised RES syllabus applies to examinations from 1 January 2027. That is different from the principal PMLPFTF amendments, which came into operation on 1 July 2025.[1][3]

What is the difference between my client and an unrepresented counterparty? Your client is the party you represent. CEA links UCPDD to the other party being unrepresented. When both sides are represented in ordinary co-broking, each RES remains focused on that RES's own client for CDD, so co-broking does not by itself create UCPDD.[5]

What is the difference between a corporate client, authorised signatory and beneficial owner? The corporate entity can itself be the client. An individual signatory or contact person can act for that client. A beneficial owner includes an individual who ultimately owns or controls an entity or legal arrangement. Do not assume these labels describe the same legal role.[9][10]

Is ECDD required for every client? No. Regulation 6 ECDD applies when a Regulation 6(2) circumstance exists. One express trigger is a relevant person who is a foreign PEP, or a family member or close associate of a foreign PEP.[11]

What is the difference between source of funds and source of wealth? Source of funds concerns the particular funds or assets used for the transaction. Source of wealth concerns the person's entire body of wealth.[7]

Does one red flag automatically mean higher risk or an STR? No. CEA's FAQ says a single common red-flag indicator does not necessarily determine higher risk. Red flags are assessment inputs. The CDSA reporting question is separately governed by the applicable knowledge-or-reasonable-grounds-to-suspect threshold.[9][15]

What happens if required client CDD cannot be completed? Regulation 12 requires the registered salesperson not to proceed with the transaction and to determine whether to file an STR.[19]

Does an RES file an STR directly, through the EA, or through SONAR? These statements describe different layers. CEA tells an RES to file an STR through the EA. SPF identifies SONAR as the electronic channel for filing STRs to STRO. Neither statement replaces the substantive legal reporting threshold.[5][15][17][18]

How are CDSA and TSOFA reporting duties different? CDSA section 45 uses a knowledge-or-reasonable-grounds-to-suspect threshold and requires disclosure as soon as reasonably practicable. TSOFA creates distinct terrorism-related duties, including immediate notification concerning terrorist property and immediate disclosure of materially helpful terrorism-financing information.[15][16]

How long are specified records retained, and what must the RES submit? Regulation 14 requires specified records to be maintained for at least five years after the relevant estate agency work. Regulation 15A requires a registered salesperson to submit specified documents and information to the licensed estate agent. This does not provide an exhaustive list of every record or document covered.[3][21]

Reconstruct the rule before answering the scenario

For a PMLPFTF scenario, reconstruct the applicable rule before concluding. Identify the relevant party and representation status, decide whether CDD or UCPDD is relevant, identify any enhanced-measure trigger, keep red flags separate from the statutory reporting threshold, and identify the actor, required action and reporting consequence. This is an organising method assembled from separate rules, not a single legal test prescribed verbatim by one authority.[5][8][9][11][15]

A single red flag or isolated scenario fact should not be treated as automatically determining the answer unless the applicable rule itself creates that consequence.[9]

Use ConfirmPass Topic 3.4 scenario practice to apply the framework by identifying the relevant party, due-diligence regime, trigger, actor, required action and possible reporting consequence from the facts.

Use the framework as a study structure: identify the relevant party, determine the applicable due-diligence branch, identify any trigger that changes the required measures, and then separate risk assessment from any reporting question.

Practise applying the Topic 3.4 framework with ConfirmPass scenarios by reconstructing the relevant obligation from the transaction facts rather than relying on acronym memorisation alone.