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2.6 The reporting process As the MLRO of your estate agency firm you have recently received reports 20 from two separate estate agents in the

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2.6 The reporting process As the MLRO of your estate agency firm you have recently received reports 20 from two separate estate agents in the service of the firm regarding transactions that they have been involved with. In the first case it was reported to you that, after the conclusion of a particular sales contract in terms of which a purchaser bought a rundown business premises for R12,9 million, a large deposit on the sales transaction - in the sum of R2,5 million - was paid by a third party on account of the buyer. The estate agent concerned advised that although he was not able to identify the third party he nevertheless believed that the buyer and the third party were not related, or even connected in any way, with each other. The estate agent indicated in his report that, at the end of the day, the transaction had fallen through. In the second case you were advised that a sales agreement for the purchase by a buyer of a residential property in an upmarket suburb for a purchase price of RB,5 million had been concluded through the reporting estate agent. According to her report, however, the name of the prospective buyer had suddenly been changed, at the very last moment, and just before the transaction was due to be closed. This change was made acting on the express instruction of the buyer. She noted that the instruction had been complied with as she did not wish to lose the sale. The transaction had thereafter been duly concluded and implemented. Discuss why you think the above transactions could be suspicious Indicate who is responsible for reporting the suspicious transactions and the process that you will follow in dealing with these two reports and C. Furnish your own report on the two matters to the principals of your firm indicating the action to be taken and possible remedies for the situation. d. Would you keep a copy of any reports that you might submit to the FIC and, if so, where will you retain them? (Insert your discussion ad your report into your POE and mark Task 3- activity 2.6)

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