AML, easy as A-B-C?

AML Compliance Officer Jade Dolman takes us through how Harcourts Team Group successfully built AML into their business-as-usual.

When AML/CFT was expanded in 2019 to include real estate, Harcourts Team Group was faced with the challenge of adjusting its sales process to include compliance with AML obligations. Selling hundreds of commercial and residential properties a year, and with a solid reputation in the real estate market, Harcourts Team Group could be a prime target for money launderers. Putting strong AML/CFT processes in place — including staff training, record-keeping, and document management — was vital in achieving AML compliance.

AML Compliance Officer Jade Dolman has been at the forefront of managing the Group’s AML compliance since late 2019. Tasked with aligning three sets of internal stakeholders with AML, Jade took a strategic approach to creating a culture of compliance through training, support from Harcourts Team Group Directors, and the latest technology.

Train, understand, repeat

The successful incorporation of AML into Harcourts Team Group’s everyday workflow was supported by robust and ongoing training and education, to help the team understand the importance of AML policies, procedures, and controls.

“Every real estate salesperson gets one-toone training with me on AML. We go over the basics and a few months later have a refresher catch-up... doing so helps them understand what their AML responsibilities are, and that it’s not as difficult as they might think, especially with the resources I provide. It also enforces the rules around AML, Harcourts Team Group is a trusted brand and so we need to be doing things right,” says Jade.

Support from all the right places

Having the support of the company Directors was vital to Jade in creating a strong culture of AML compliance.

“As a Compliance Officer, it’s great to have management take what I say very seriously, especially as sometimes you must ask people for more information or deal with someone who is not happy giving it to you.

“While I am supported by our Directors, I make sure that, in turn, I’m giving support to agents and staff. They can contact me at any time and know that I will always answer. And I always say to them that spending a bit more time with me to get the right answer is important — no one wants to take the wrong answer to their client. So, making sure the team feels supported and has the right tools is essential,” adds Jade.

Technology for a smoother process

The use of technology has helped Harcourts Team Group smooth the transition into an AML/CFT regime and embed their new approach to managing AML through the transaction process by giving agents the flexibility to upload documents in the field, from anywhere in New Zealand.

“Using specialised AML technology (AMLHUB), agents can collect documents by using their phones rather than having to bring it all back to the office to scan. It makes everyone’s life easier. And because this tech is hosted in the cloud, it also means I can do my job from anywhere, which was especially important during the COVID-19 lockdowns.

“This new process also helps establish clear boundaries and expectations. If it’s [the property transaction] not verified in the software, there will be nothing happening with the property until it is.”

All this hard work by Jade and her team paid off when the business underwent an onsite inspection by the Department of Internal Affairs (DIA) — and passed with flying colours.

“We had a random inspection by the DIA, who came in and looked through everything: our Compliance Programme, all my training material, the suspicions register on the AMLHUB, and they randomly picked some salespeople and managers to interview. They came back to me after that, and they didn’t have any issues with anything.

“I’m thorough with our AML, and I use the AMLHUB, so I didn’t feel like there was anything more I could have done to prepare... that was a personal victory for me. I felt so proud that every person they spoke to within our company, and everything they’d looked at, had been satisfactory to them.”

Peace of mind

Bringing a large company into alignment with the AML/CFT regime is no small feat. Having conquered the challenges in building out a comprehensive AML programme and workflow for a large real estate agency, Jade has advice for anyone looking to move into the AML/CFT compliance space.

“Be there for the people who rely on you for information. It’s a big responsibility. Check and recheck everything you send out because it’s important to get it right. Build your support network around you, especially senior management, so you’re enabled to do your job. Be diligent about recording the reasoning behind the decisions you make. Be open to advice and guidance because we’re all here for the same reason,” Jade concludes.

Five red flags real estate professionals should watch out for:

1. Property value is under or over-priced 2. Large amounts of cash are used

3. Client has access to funds that don’t match their business or personal profile

4. Client is located in a foreign country, especially one known for a weak AML regime

5. Payments are received from an unknown third party.

Jade Dolman, AML Compliance Officer, Harcourts Team Group