Practice question
A real estate broker accepts a transaction showing clear suspicious indicators but says the amount is below the sector's covered-transaction threshold, so no AML reporting duty can arise. The broker is a covered person and no privilege exception applies. Which is best?
- Suspicious transactions are reportable regardless of amount when their statutory conditions are met
- Only above-threshold transactions can ever be suspicious
- A broker can opt out of covered status by contract
- Only bank transactions can be suspicious
- Every below-threshold transaction is conclusively legitimate
Legal references
- RA 11521 Section 2; RA 10365 Section 7: https://lawphil.net/statutes/repacts/ra2021/ra_11521_2021.html ; https://lawphil.net/statutes/repacts/ra2013/ra_10365_2013.html
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