JLL is required to conduct transactions such that we do not knowingly or unknowingly participate in schemes that are illegal and/or used to launder money. There is also mounting international pressure on governments to apply more stringent “Know Your Client” (KYC) rules to the real estate industry as part of the Anti-Money Laundering (AML) drive. The Global Compliance team is reviewing AML and KYC policies and procedures across the globe to help identify risk gaps and recommend best practices.
In the meantime, please take the time to read JLL’s Risk Management Guideline 12 – Anti-Money Laundering which provides a useful list of “red flags” to identify suspicious circumstances and transactions. The bottom-line is that even if a jurisdiction does not currently impose any KYC requirements on real estate service providers/professionals, we should minimize the risk that we are unwittingly used to help launder money through real estate transactions. If you recognize any of these red flags in transactions that you work on, please escalate to Legal & Compliance.