Dealing with AML Risks in Real Estate

Start Time

08:30 AM

End Time

12:30 PM


Aruba, Caya Taratata 3-A, Unit 16.


As of January 1, 2020, the updated Anti-Money Laundering/Combatting the Financing of Terrorism (AML/CFT) Handbook of the Central Bank of Aruba (CBA) has been in force, which is also applicable to Real Estate Agents and Brokers.
Real Estate Agents and Brokers can consciously or unconsciously play a facilitating role in money laundering and terrorist financing.
While the illicit finance risk for Real Estate Agents and Brokers are often mitigated by the involvement of financial institutions already subject to strict AML laws, the use of real estate in money laundering schemes continues to be an area of concern. However, when a transaction steps outside the norm or in cases where certain risk factors are present, a real estate agent could face an elevated chance of encountering a possible money-laundering scheme and should consider taking measures to address the risk.
The purpose of the AML/CFT State Ordinance is to prevent the Real Estate Agents and Brokers from being abused to launder money, to mask the criminal origin of money or to finance terrorist activities. The most important pillars of the AML/CFT State Ordinance are performing customer due diligence and reporting unusual transactions.


The following topics are discussed:

  • How to conduct/update an AML/CFT Risk Assessment & consequently update the AML/CFT Compliance Manual
  • How and when to conduct Customer Due Diligence (Simplified, Standard and Enhanced)
  • How to determine risk profiles (Low, Standard (Medium) & High)
  • Client acceptance procedures in particularly Politically Exposed Persons (PEPs)
  • Identification and verification of the ultimate beneficial owner or controlling person.
  • Identifying persons that are listed on sanction lists c.f. the Sanction State Decree Combat Terrorism and Financing Terrorism and other Sanction State Decrees (Aruba).
  • Identifying persons from jurisdictions which do not or insufficiently comply with internationally accepted standards for the prevention and combating of ML and TF (e.g., FATF recommendations)
  • When to request a Source of Funds/Source of Wealth
  • When and how to monitor business relationships, aimed at the risk profile of the client and, if applicable, into the Source of Funds/Source of Wealth
  • Identifying of unusual transactions (subjective indicator) and the timely reporting to the FIU
  • The role and responsibility of the Money Laundering Compliance Officer (MLCO) & the Money Laundering Reporting Officer (MLRO)
  • Record keeping of the conducted customer due diligence/enhanced customer due diligence and identification documents.
  • Content of a Compliance Management Report to Management
  • AML/CFT Training Program
  • What should be assessed by the External AML Audit (outsourced)

Target audience:

  • Real Estate Agents and Brokers
  • All relevant service providers dealing with Real Estate Agents and Brokers e.g., notaries

After this training you will understand why real estate is attractive to money launderers. What you can do to mitigate risks. Also, how to identify red flags for money laundering, and the steps to take to report unusual transactions.


There are no requirements for participation.

Duration of the training

The duration of the training is 4 hours.


AWG. 445,- pp. (incl. taxes)

Costs includes: Training sheets and Certificate of participation.


Date: July 7, 2021

Time: 8:30 – 12:30

Location: This training will be held at the training center of Compliance Services Caribbean located at Caya Taratata 3-A, Unit 16 (Opposite RBC Bank Italiëstraat).