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GACO Real Estate Agent AML/CFT/CPF Training - 6th June 2023

18 May 2023

According to the Organisation for Economic Co-operation and Development (OECD), money laundering through real estate is one of the oldest known ways to move and hide illicit funds. Property companies need robust AML compliance policies and real estate professionals need regular up-to-date training.

We all have read in the press that several local Real Estate Agents have recently been fined for non-compliance with the local AML regulation. This clearly highlights the need for a thorough AML/CFT/CPF Training focused on the needs of local Real Estate Agents.

GACO is happy to inform that in conjunction with Jo Abergel Director of RockLearning Gibraltar we have been able to engage Michael Adamberry as the speaker for this event with a Question and Answer session with Francis Muscat and Tamara Gafan forming part of the session.

You can raise any questions that you want to be discussed and answered at said event by sending an email to as soon as possible and no later than 2nd June. We will make sure that the question is then raised at the event.

If you are a Real Estate Agent based in Gibraltar, this is the event that you SHOULD NOT miss. Please make sure to register today for it, pay the fee and attend the same. GACO has kept attendance fees to a minimum.

Bookings - Click here

Event Details

Date: Tuesday 6th June 2023
Time: 9:30am - 1:00pm
Location: Board Room, Gibraltar Finance Center
Fees: GBP 35.00 GACO Members/GBP 50.00 Non-GACO Members

Content Outline

  • Introduction to money laundering (ML), terrorist financing (TF), and proliferation financing (PF) and how these occur
  • Key principles of anti-money laundering (AML), countering financing of terrorism (CFT) and counter-proliferation financing (CPF) laws and regulations and how they apply to the Real Estate Sector
  • Application of different levels of customer due diligence
  • Applying the risk-based approach
  • Recognising and reporting suspicious activity, including spotting the red flags in your sector
  • Understanding predicate offences
  • Understanding the consequences of non-compliance with AML/CFT/CPF regulations, both for regulated businesses and their individual employees

The presentation will be supplemented with scenario-based training, focusing on some of the more common ‘problem areas’ encountered:

  • Ultimate beneficial ownership
  • Source of funds and source of wealth (SOF/SOW)
  • Politically Exposed Persons (PEPs)
  • Targeted Financial Sanctions (TFS)Ongoing monitoring
  • Developing risk assessment frameworks and the importance of the Business Risk Assessment
  • Setting AML/CFT policies, controls and procedures
  • Using the National Risk Assessment and considering country risk
  • Record-keeping
  • Reliance
  • Working as part of a larger corporate group

The session will conclude with a Question and Answer session with Francis Muscat and Tamara Gafan from the OFT. Please send all questions to by no later than 2nd June.

Our Speakers

Michael Adamberry

Michael is an Associate at ISOLAS LLP, specialising in Data Protection & Privacy Law. He is a Certified EU GDPR Practitioner (2018), and has significant experience in advising on implementation and compliance with data protection legislation including Gibraltar GDPOR, EU GDPR, the law enforcement directive, and the ePrivacy framework.
Michael has advised a wide range of clients ranging from sole traders and SMEs, to large multi-national corporates, public authorities, Her Majesty’s Government of Gibraltar (HMGoG), financial institutions, and insurance companies.

As a former regulator at the Gibraltar Financial Services Commission, Michael is also called upon for his expertise in Banking & Regulatory Compliance Services, with focus on AML/CFT/CPF & Financial Crime. He assisted in edits to the first edition of the anti-money laundering guidance notes for Gibraltar’s legal profession and advised HMGoG on implementation of 5AMLD & 6AMLD, as well as assisting in the drafting of the Proceeds of Crime (Miscellaneous Amendments Act) 2021 and related legislation as part of Moneyval’s Mutual Evaluation Report for Gibraltar regarding the FATF’s revised standards.

Michael a dually qualified Solicitor & Barrister, frequently assisting the Dispute Resolution and Shipping & Admiralty teams on litigation matters. He was recently ranked as a “Rising Star” in Shipping by the Legal500 EMEA.

Francis Muscat

Francis is the Chief Executive Officer of the Office of Fair Trading, a business regulator established by HM Government of Gibraltar responsible for business licensing, consumer protection and anti-money laundering & countering the financing of terrorism supervision. Francis has carried out this role since the OFT’s commencement in October 2015 and has advised multiple Ministers in relation to wide-ranging legal, policy and business-related matters.

Francis was an Associate of Hassans International Law Firm from December 2007 to August 2015 where he developed extensive experience in international Corporate transactions with an underlying emphasis on re-financing and acquisitions of commercial property. He has also advised on a broad range of Gibraltar corporate law issues relating to various types of transactions, including the establishment of corporate structures and the use of Gibraltar-based entities.

Tamara Gafan

Tamara became an AML/CFT Officer at the Office of Fair Trading at the beginning of 2020. She has contributed to creating the OFT’s AML/CFT policies and procedures and the OFT’s AML/CFT guidance for its regulated entities. Tamara is responsible for the OFT’s onsite visit process.

Tamara has a BA in Communication Studies from Middlesex University. Upon joining the Civil Service, she worked at the Royal Gibraltar Police’s Records Department and later moved to the Treasury Department where she spent five years before being promoted and stationed at the OFT.

Bookings - Click here