Given the intense interest, in tax haven corporations, generated by the information released in the Panama Papers scandal, real estate professionals in the United States should follow a prudent course of action, and create an AML/CFT compliance program in-house, to insure that they will not be the subject of unwanted law enforcement attention, or even criminal indictment, for failing to apply effective Know your Customer procedures.
It is humbly suggested that all those involved in the real estate sector consider these steps, though voluntary under existing laws, as measures which they should consider mandatory, for proper risk reduction in their firm. All real estate offices should follow this course of action:
(1) Create an anti-money laundering compliance program, with a written compliance manual.
(2) Designate a Compliance officer, and see that he or she is properly trained.
(3) Conduct a semi-annual AML/CFT training program for all employees, including the support staff.
(4) Arrange for an outside compliance audit, on a semi-annual basis.
(5) Reach out the regulatory and law enforcement community, and build a network of contacts, whom you may call upon with questions about operations, as well as suspicious individuals or entities.