Identify the following individuals.

• A. Any individual who conducts a large cash transaction, any individual or identity for whom a client information record or a receipt of funds record is kept, and any individual for whom a suspicious transaction report is sent.
• B. Only customers
• C. Only staff members at the brokerage
• D. Only individuals who submit forms

Answer: (A)

In anti-money laundering rules for real estate, the focus is on everyone connected to the transaction who affects funds, identification, or reporting. The correct answer reflects all individuals who trigger AML obligations: anyone who conducts a large cash transaction because that activity must be reported; any individual for whom a client information record or a receipt of funds record is kept because these records are part of verifying and tracking clients and funds; and any individual for whom a suspicious transaction report is sent because that process exists for screening and flagging unusual activity. In short, AML rules apply broadly to people tied to the transaction, not just customers or staff, and not just those who submit forms.

The other options are too narrow: focusing only on customers or only on staff misses other parties involved or sources of funds, and focusing on form submitters ignores the record-keeping and reporting requirements that involve a wider set of individuals.