Please read the following information before proceeding to begin the supplemental AML risk assessment questionnaire.
This Supplemental AML risk assessment questionnaire is to be completed and submitted on or before February 28, 2025. It is to be completed by ALL real estate dealers who are natural persons (individuals) or legal persons (corporate bodies) that conducted any type of real estate business transaction (as specified in the Real Estate Dealers and Developers Act) over the period Janauary 1, 2020 to December 31, 2024. In addition, real estate dealers who are employed to other real estate dealers MUST complete and submit this AML risk assessment questionnaire. The Supplemental AML Risk Assessment Survey will play an integral role in determining the AML risk profile of the real estate sector for the period January 1, 2020 to December 31, 2024, which is needed for Jamaica to fulfil its international obligations to the Financial Action Task Force (FATF). It should also be noted that the real estate sector consists of the second highest number of designated non-financial institutions (DNFIs) in Jamaica. Further guidance is provided on completing the risk assessment questionnaire below.
Guidance Notes on Completing the Supplemental AML Risk Assessment Questionnaire
- If a respondent is a dealer licenced in his or her individual name or Trading As Name (as a natural person) and is also the Qualifying Director for a real estate dealer that is registered as a corporate body/company, he or she must complete the risk assessment questionnaire TWO TIMES - once in his or her capacity as a dealer operating as a natural person and another time in his or her capacity as a qualifying director.
- If a respondent is a dealer that's licensed in their individual name or Trading As Name (as a natural person) and is practising as such, he or she must complete the AML risk assessment questionnaire.
- If a respondent is a dealer that's licensed in their individual name or Trading As Name (as a natural person) is employed to another real estate dealer and is not a qualifying director, he or she must complete the risk assessment questionnaire as a dealer who is licensed to practice in their individual name or outside of the dealer to whom or to which they are employed.
- In situations where individuals who are licensed as real estate dealers come together and form a partnership firm, each dealer (i.e. each partner in the firm) must complete this questionnaire.
- In situations where a dealer that is registered as a corporate body/company has more than one qualifying director, only the managing (or lead) quaifying director is to complete the risk assessment questionnaire on behalf of the dealer that is registered as a corporate body/company.
- In situations where a dealer that is registered as a corporate body/company has qualifying directors for different areas of real estate business, only one qualifying director is to complete and submit the AML risk assessment questionnaire on behalf of the corporate body/company. It therefore means that the qualifying director that will be completing the questionnaire must complete it by answering the questions therein based on ALL the data required by the question.
- If a respondent is the managing (or lead) qualifying director for more than one corporate body/company that is registered as a real estate dealer OR if a respondent is the qualifying director for more than one corporate body/company that is registered as a real estate dealer, the respondent must complete the Supplemental AML risk assessment questionnaire for each corporate body/company for which he or she is the qualifying director or managing (or lead) qualifying director.
- If a respondent has a dealer's licence in their individual name that was on placed on dormancy prior to or during the period of January 1, 2020 to December 31, 2024 he or she will be required to complete the risk assessment questionnaire.
- After submitting the questionnaire you will be redirected to the Real Estate Board's website after which you may close the webpage.
The questionnaire consists of approximately 3 pages. Respondents are being encouraged to complete the form by using a laptop or desktop computer rather than on a tablet or mobile phone. If you are unsure of how to answer a question when completing the questionnaire or if you're experiencing any difficulties, please contact the AML Unit at the email address aml@reb.gov.jm