RES learning guide

AML, PF and TF controls

Apply the risk-based process in order: identify, assess, verify, monitor and report. Do not collapse distinct duties into one slogan.

Built for the RES examination syllabus that applies from 1 January 2027. CEA has published a revised syllabus for examinations from that date. Examinations held in 2026 and earlier use the RES Examination Syllabus 2017 instead. The remaining 2026 papers are sat on 31 October 2026 and 1 November 2026; if that is your sitting, treat this as revision of the law rather than as a rehearsal of your blueprint, because the two syllabuses examine the same statutes under a different structure.

What changed between the two syllabuses · CEA's own statement of which syllabus applies

A reliable way to study this topic

  1. 1. Classify the factsName the transaction, person, document and date before recalling a rule.
  2. 2. Find the authorityRead the exact provision or regulator rule. Note what it does not cover.
  3. 3. Apply, then calculateUse the facts in the order the rule requires. Keep assumptions visible.
  4. 4. Test the edgesAsk what changes if the date, status, property type or client changes.

Apply it: AML, PF and TF controls questions

Every Freehold question shows why the right answer is right — and cites its source.

Under the Estate Agents (Prevention of Money Laundering, Proliferation Financing and Terrorism Financing) Regulations 2021, what is the primary purpose of the customer due diligence and unrepresented counterparty due diligence duties placed on real estate salespersons and estate agents?

  1. To let CEA collect data for setting annual property price ceilings, which are usually revised each budget cycle
  2. To position RESs and EAs as the first line of defence against money laundering, proliferation financing and terrorism financing risk in property transactions, given the large sums typically involved
  3. To help IRAS calculate the buyer's stamp duty and additional buyer's stamp duty liability
  4. To satisfy a purely internal CEA record-keeping requirement with no link to Singapore's wider anti-money-laundering regime
Show answer & explanation

To position RESs and EAs as the first line of defence against money laundering, proliferation financing and terrorism financing risk in property transactions, given the large sums typically involved — CEA states RESs and EAs are the first line of defence against ML/PF/TF because property transactions moving large sums are an attractive channel for criminals, which is why Singapore's FATF-aligned regime places CDD and UCPDD duties on them.

Source: CEA — Preventing money laundering, proliferation financing, and terrorism financing Roles of real estate salespersons and estate agents · checked 2026-08-18

A salesperson suspects a client is connected to money laundering after screening the client against the FATF high-risk jurisdiction lists and the UN Sanctions List under the Terrorism (Suppression of Financing) Act 2002. What is the salesperson's required next step?

  1. Personally investigate the client's finances before deciding whether to report
  2. Proceed with the transaction as normal, since only the estate agent (not the salesperson) has any reporting duty
  3. Wait until the transaction completes, then report the matter to CEA's disciplinary committee
  4. File a Suspicious Transaction Report through the salesperson's estate agent via STRO's SONAR system, and cease dealing with the client in that transaction unless an Exemption Order has been obtained
Show answer & explanation

File a Suspicious Transaction Report through the salesperson's estate agent via STRO's SONAR system, and cease dealing with the client in that transaction unless an Exemption Order has been obtained — CEA states that a salesperson who suspects ML/PF/TF connections must file an STR through their estate agent to STRO and stop dealing with the client, and is not expected to conduct their own investigation, unless an Exemption Order under TSOFA applies. A salesperson is not expected to personally investigate the client's finances, proceeding with the transaction as normal is wrong since the salesperson does share the reporting duty, and waiting until completion to report to a disciplinary committee misdescribes both the timing and the correct recipient of the report.

Source: CEA — Preventing money laundering, proliferation financing, and terrorism financing Reporting Suspicious Transactions · checked 2026-08-18

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