On 18th December, an article from Dentons says that on 20th November, the parliament passed the Developers (Anti-Money Laundering and Terrorism Financing) Bill (the AML Bill).  It says that real estate has been flagged out as one of the target non-financial sectors that may encounter money laundering and terrorism financing activities.  The article details the Bill’s objectives, and the key responsibilities and duties of developers introduced by it.  Developers must not open or maintain any account for, or hold and receive moneys from an anonymous source or a purchaser with an obviously fictitious name, and developers must perform prescribed CDD measures.  A developer must also implement adequate programmes and measures to prevent money laundering and terrorism financing, as well as having adequate record-keeping and the ability to report suspicious transactions.  The new law introduces a new definition of ‘purchaser’ which is very wide and refers to a person to whom the developer grants an Option to Purchase or who agrees to purchase a unit from the developer, and includes a prospective purchaser.  Those convicted of money laundering and terrorist financing offences may not be developers.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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