AML compliance in real estate: what agencies need to know

In the fight against money laundering and terrorism financing, the real estate sector has emerged as a growing area of concern for regulatory authorities. Across the European Union and in Luxembourg in particular, real estate professionals—including agents, developers, and property managers—are now under increasing pressure to comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.

Why is the real estate sector under scrutiny?

Real estate transactions are often high-value and can be used to obscure the origins of illicit funds. For criminals, purchasing property is an effective way to integrate illegal money into the legitimate economy. As a result, AML regulations now require real estate professionals to conduct robust due diligence on clients and transactions.

Who is affected by these AML obligations?

In Luxembourg and across Europe, AML compliance is not limited to banks and financial institutions. The scope of the AML Directive (AMLD) includes “non-financial professions” such as notaries, lawyers, and real estate professionals. Agencies involved in buying, selling, or renting properties on behalf of clients must now adhere to specific obligations under the law.

What are real estate agencies required to do?

The key AML/KYC (Know Your Customer) responsibilities for real estate agencies include:

Customer due diligence (CDD): Agencies must verify the identity of their clients, whether they are individuals or legal entities. This includes understanding the ownership structure and identifying the Ultimate Beneficial Owner (UBO).

Risk-based approach: Professionals must assess the level of AML risk for each client and transaction. Factors like the source of funds, country of origin, and transaction type must be considered to determine the appropriate level of due diligence.

Ongoing monitoring: Compliance doesn’t stop after onboarding. Agencies must monitor the business relationship, ensuring any unusual or suspicious activity is promptly identified and reported to the relevant authorities (e.g., the CRF in Luxembourg).

Record-keeping: Documents and records related to identity checks, risk assessments, and transactions must be retained for a minimum period (usually five years), as stipulated by local regulations.

Staff training and internal procedures: Agencies are expected to establish internal AML procedures and provide regular training to ensure all staff are aware of their responsibilities.

What are the risks of non-compliance?

Failure to comply with AML regulations can lead to significant consequences, including:

• Administrative sanctions and fines
• Reputational damage
• Legal liability, including potential criminal charges

With regulators increasingly focusing on the real estate sector, compliance can no longer be viewed as optional or secondary.

Simplify AML compliance with Apentis AMLscorer

Navigating AML compliance requirements can be complex and time-consuming for real estate professionals. That’s why at Apentis we developed AMLscorer—a powerful, easy-to-use platform that helps real estate agencies automate client risk assessments, streamline document collection, and stay compliant with evolving regulations.

Whether you need to identify UBOs, score client risk, or manage missing KYC documents, AMLscorer is designed to simplify the entire process—without compromising on security or accuracy.

👉 Learn more on our AMLscorer product page, or contact us to schedule a free demo and see how AMLscorer can help your agency stay compliant.