This Practice Note will provide an overview of how an organisation carries out financial activities which are subject to AML regulations and to what extent the AML regulations are applicable to it.

• AML: Anti-money laundering.

• CFT: Countering the financing of terrorism.

• Beneficial owner: The natural person who ultimately owns or controls a customer, through ownership interest or voting rights, or the natural person on whose behalf a transaction is being conducted, whether by proxy, trusteeship or mandate, or by any other form of representation. It also includes any person who exercises ultimate effective control over a legal person or arrangement, including any person exercising ultimate effective control by any means.

• Business relationship: A continued relationship arising between a client and a financial institution or designated non-financial business or profession regarding the services they provide to them.

• Customer: Any person or legal arrangement dealing with financial institutions or designated non-financial businesses and professions.

• CDD: Customer due diligence.

• EDD: Enhanced due diligence.

• Designated non-financial businesses and professions (DNFBPs): Any of the following businesses, activities, or professions:

  • Real estate brokers whenever they conduct transactions related to the sale and purchase of real estate, or both, for the benefit of clients.