07/10/2026
In AML/CTF Check-In Session 3, our panel worked through one of the most debated timing questions under Tranche 2.
🔹Vendors: CDD should start at initial instruction, once the client has engaged you to prepare the contract.
🔹Purchasers: The starting point is still that CDD is completed before you begin providing the designated service. The AML/CTF Rules do allow initial CDD on a buyer to be delayed, but only where the conditions for delay are met and your AML/CTF program provides for it. Where delay applies, CDD must be completed no later than 28 days after exchange or 3 days before the originally agreed settlement date, whichever comes first.
Delay is an exception to apply carefully, not a default. If you rely on it, make sure you can show why it applied to that client and that their risk profile supported it.
The grey area is the purchaser who only wants a contract reviewed before committing. Think of a 3pm Friday call before a Saturday auction. Advising on the legal effect of a contract is different from advancing a purchase, such as negotiating terms, advising across several properties or helping with due diligence on the property. Once your work moves into that second category, you're likely providing the designated service, and your CDD obligations need to be met or the delay properly justified.
Watch the full panel discussion on when CDD should begin: https://ap1.hubs.ly/H01qxDr0
