---
name: compliance-flag-checker
description: "Flag AML, GDPR, DMCCA 2024 material information, ASA/CAP advertising standards, and Equality Act risks in any output before the operator approves it. Cross-cutting skill called by every workflow that produces an outbound message, a listing, terms of business, or a payment batch. Owned by the compliance specialist."
---

# Compliance flag checker

A cross-cutting building-block skill. Runs against every output that touches a regulated surface (a portal listing, a terms-of-business document, an outgoing message to a buyer or vendor, a payment batch, the AML status on a deal). Returns a list of flags the operator should see before approval.

## What it checks

- **Material information.** DMCCA 2024 disclosure requirements for property listings: council tax band, tenure, ground rent and service charge if leasehold, property type, construction, utilities, heating, broadband, parking, and the wider Part C signals (flood risk, listed status, structural issues, planning permission, mining, and the rest). Missing items are flagged with the specific legislative requirement.
- **Advertising standards.** ASA upheld-complaint patterns: fee transparency (VAT inclusion, mandatory surcharges disclosed), property descriptions accurate and substantiated, "local" claims supported, "leading" and "number one" claims substantiated.
- **EPC display.** Asset rating present in any commercial media for the listing.
- **AML state on the vendor.** Blocks a portal launch unless AML status is "passed" or the operator has explicitly overridden.
- **GDPR.** Marketing messages to non-existing-client contacts checked for PECR opt-in basis. Data-retention prompts surfaced on close files.
- **Equality Act.** Listing copy and outgoing messages checked for discriminatory phrasing (most commonly the "No DSS" pattern in lettings, court-declared as unlawful indirect discrimination).
- **EAA s.21 personal interest disclosure.** Flags any output where the agent has a personal interest in the property and the disclosure has not been made.
- **Renters' Rights Act 2025.** Where the workflow produces lettings output: bidding-ban compliance (must publish asking rent, must not request or accept above-advertised offers), discrimination ban (benefits, children), pet provisions, PRS database registration check, ombudsman membership display.
- **Client money handling.** EAA 1979 ss.12 to 17 obligations on prescribed accounts, interest, trust requirements.

## Output

Each flag returns:

- The cited legislation (Act, SI, regulation, code provision), with format like `[DMCCA 2024, Part 4, s.237]`
- The specific issue
- The remediation required
- The penalty exposure for non-compliance

The calling workflow surfaces the flags at the top of the staged output. The operator clears the flags or accepts the residual risk before approving.

## What it does not do

- It does not block approval. The operator decides; the skill informs.
- It does not provide legal advice. Use "the legislation requires", "the regulatory position is", "this appears to fall short of". Never "you should" or "my advice is".
- It does not certify a transaction or a listing as compliant. It flags gaps and cites requirements.
- It does not amend the output it checks. Remediation is for the calling workflow or the operator.

## Connectors

Read: profile (compliance state, AML provider, scheme memberships), CRM (deal, vendor, listing), the deep-research tool when an unfamiliar provision needs verification.
Write: none.

## Profile keys

- `realagent.compliance.cmp_scheme_membership`
- `realagent.compliance.redress_scheme`
- `realagent.compliance.ico_registration`
- `realagent.compliance.mlro_designation`
- `realagent.compliance.aml_provider`
- `realagent.compliance.tpo_membership`
- `realagent.compliance.propertymark_membership`
