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Which CEA AML forms do I need?

CEA publishes thirteen due diligence forms across two annexes, and which of them a transaction needs depends on who your client is, whether they are acting for someone else, whether an unrepresented counterparty is involved, and whether the risk assessment concludes that the situation is higher risk. Answer the questions below and the required set is named, with the reason each one applies.

One answer short-circuits everything else: a tenancy of an HDB flat wholly for residential use is exempt from customer due diligence, so no forms are required at all. The duty to file a Suspicious Transaction Report still applies if suspicion arises, and a tenancy covering the commercial space of an HDB shophouse is not exempt.

The standard workflow

CEA sets out the sequence below. The gate at step seven is the one most often missed: due diligence has to be complete before the Option to Purchase is issued or exercised and before a Tenancy Agreement is signed — not before completion.

  1. Engage — sign the estate agency agreement with the client before starting work.
  2. Identify — collect particulars and verify the identity of the client, beneficial owners and any principal; establish authority where a representative acts.
  3. Screen — run TSOFA, UN, FATF and CEA-list screening and PEP checks; capture evidence.
  4. Assess — complete the red-flag checklist and record a genuine risk conclusion.
  5. Escalate if higher risk — perform enhanced due diligence and obtain the Compliance Officer’s approval before proceeding.
  6. UCPDD — once the deal is likely to proceed, complete due diligence on any unrepresented counterparty.
  7. Gate — confirm ALL due diligence is complete before the OTP is issued or the TA is signed. If it cannot be completed, do not proceed.
  8. Submit — send every form, screenshot and supporting document to the Agency; delete identification images from personal devices afterwards.
  9. Report — if suspicion arises at any point, escalate to the Compliance Officer within 24 hours and ensure an STR is filed. Never tip off.

Every form named by the selector has its own page with completion notes and common mistakes — see the compliance category.