For six years, a New Zealand real estate agency accepted client funds into a trust account that no auditor ever examined — not because the money was mishandled, but because the oversight mechanism itself was never put in place. One Up Realty was fined $18,000 last month after admitting to reckless contravention of the Real Estate Agents Act 2008, a case that reminds the industry that structural safeguards exist not only to catch wrongdoing, but to prevent the conditions in which wrongdoing becomes possible. The absence of harm, regulators made clear, is not the same as the presence of complian