Anti-Money Laundering (AML) Checks for Estate Agents

February 11, 2024

Working in real estate involves more than just property transactions; it's about trust and accountability. In this blog, we introduce you to the Anti-Money Laundering (AML) checks for estate agents.

AML for estate agents can be time-consuming, involving tasks like verifying identities and checking proof of funds. This blog introduces a more advanced, faster, and user-friendly alternative to streamline these procedures and processes.

AML Checks for Estate Agents

AML checks for estate agents are the set of procedures and measures implemented by real estate professionals to prevent and detect activities related to money laundering and other financial crimes.

The real estate sector can be vulnerable to money laundering due to the large sums of money involved in property transactions. The purpose of these checks is to ensure that individuals involved in property transactions are not using real estate transactions as a means to launder money.

In KSA, for instance, real estate agents or real estate offices should comply with the Anti-Money Laundering Law and its executive regulations. According to the Ministry of Commerce and Investment in Saudi Arabia, money laundering in real estate is commonly associated with societies that heavily rely on cash transactions. The methods and techniques employed for money laundering in real estate vary based on the specific approach and characteristics of buying and selling within this industry. Therefore, AML for estate agents is mandatory in KSA.

Example: HMRC Penalties for Estate Agents

In 2022, HM Revenue and Customs (HMRC) disclosed that 68 estate agents have collectively been fined £519,645 for violating anti-money laundering regulations, marking the first prosecution of an estate agent for trading without registering with HMRC. 

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Indicators of Suspicious Activities in Real Estate Transactions

Indicators of unusual or suspicious activities in real estate transactions serve as signals that something out of the ordinary or potentially illicit may be occurring. These signs include:

  • Buying or selling real estate at a significantly deviated price compared to market values.
  • Repeated purchases of properties inconsistent with the buyer's usual financial capacity or suspicions of transactions for others.
  • Registering a personal property under a client-owned company.
  • Requesting redesign or improvements on a property, paying in cash, and intending to resell at a higher value.
  • Large cash deposits followed by a refusal to complete the purchase, requesting the deposit value in a check.
  • Payment of a necessary deposit using a check issued by a third party with a dubious or unclear relationship to the client.
  • Lack of interest in inspecting the property before purchase.
  • Rapid acquisition of multiple properties without consideration for location, condition, or repair costs.
  • Selling a property without concern for the price.
  • Registering or mortgaging a property under another person's name to conceal ownership.
  • Purchasing property at an inflated price with an agreement to return the difference outside government channels.
  • Immediate selling of a property after purchase at a lower price.
  • Payment for real estate using funds from high-risk countries.
  • Requesting transfer of real estate funds to a high-risk country.
  • Engaging in complex operations involving purchasing, reselling, exchanging, or trading real estate.
  • Reluctance to associate one's name with property files or use different names during purchase offers.
  • Purchasing properties in the name of an unrelated person.
  • Last-minute replacement of the buyer's name without sufficient justification.
  • Financing transactions through unusual or foreign sources.
  • Execution of operations to conceal the illegal source of money as part of the layering phase.
  • Investing in tourist resorts to provide a legal appearance to money during the integration phase.
  • Buying and selling real estate using fictitious names.
  • Purchasing a property below its actual value and later reselling it at its true price often involves cooperation with a seller willing to acknowledge the sale for a lower price and accepting the difference in secret.

Key Aspects of AML Checks for Estate Agents

The AML checks for estate agents include but are not limited to:

1. Customer Due Diligence (CDD)

Estate agents are required to conduct thorough background checks on their clients, including buyers and sellers. This involves verifying the identities of the parties involved and assessing the legitimacy of their funds.

2. Enhanced Due Diligence (EDD)

In certain high-risk situations, estate agents may need to go beyond standard CDD and conduct enhanced due diligence. This involves gathering additional information about the client and the transaction to mitigate higher risks.

3. Transaction Monitoring

Estate agents need to monitor transactions for any unusual or suspicious activities. This includes identifying transactions that deviate from the norm or that exhibit red flags associated with money laundering.

4. Record-Keeping

Maintaining detailed records of transactions, customer information, and AML checks is a fundamental aspect of compliance. This documentation serves as evidence of compliance and can be crucial in case of regulatory inquiries.

5. Source of Funds (SOF) and Source of Wealth (SOW) Verification

Agents need to verify the source of funds used in property transactions. This involves ensuring that the funds come from legitimate sources and understanding the client's overall wealth.

6. Training and Awareness

Estate agents must ensure that their staff members are adequately trained and aware of AML regulations for estate agents. This includes providing training on recognizing and reporting suspicious activities.

7. Risk Assessment

Conduct risk assessments to identify and evaluate the potential money laundering risks associated with specific clients, transactions, or geographic areas.

8. Compliance with Regulatory Requirements

Estate agents need to stay abreast of relevant AML regulations for estate agents and comply with the guidelines set by regulatory authorities. This may include adhering to specific reporting requirements and timelines.

Risk Assessment Strategies in Real Estate Transactions

Risk assessment and management in real estate transactions involve identifying, evaluating, and mitigating potential risks associated with property dealings. Here are key considerations for understanding and implementing effective risk assessment and management in the real estate sector:

1. Identification of Risks

  • Identify various types of risks, including financial, legal, regulatory, and market risks.
  • Recognize specific risks associated with different stages of real estate transactions, from listing to closing.

2. Due Diligence

  • Conduct thorough due diligence on properties, including title searches, environmental assessments, and zoning checks.
  • Verify the legitimacy of property documentation and ownership to minimize legal risks.

3. Market Risks

  • Analyze market trends and conditions to assess potential fluctuations in property values.
  • Consider economic factors that may impact the real estate market, such as interest rates and inflation.

4. Financial Risks

  • Evaluate the financial stability of involved parties, including buyers, sellers, and lenders.
  • Assess the risk of default on mortgages or loans associated with the transaction.

5. Regulatory Compliance

  • Stay informed about and comply with local, regional, and national regulations affecting real estate transactions.
  • Ensure adherence to Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements.

6. Environmental and Physical Risks

  • Assess environmental risks, including contamination and potential hazards, associated with the property.
  • Evaluate the physical condition of the property, identifying maintenance or structural issues.

7. Transaction Structure

  • Consider risks related to the chosen transaction structure, such as lease agreements, joint ventures, or financing arrangements.
  • Evaluate the impact of transaction terms on potential risks and liabilities.

8. Legal Risks

  • Identify legal risks, including potential disputes, zoning violations, or encumbrances on the property.
  • Work with legal professionals to ensure compliance with laws and regulations throughout the transaction.

9. Insurance Coverage

  • Assess the need for insurance coverage to mitigate risks associated with property damage, liability, or title issues.
  • Ensure that insurance policies provide adequate protection for potential risks.

10. Mitigation Strategies

  • Develop and implement risk mitigation strategies based on the identified risks.
  • Establish contingency plans to address unforeseen challenges that may arise during the transaction.

11. Documentation and Communication

  • Document all aspects of the risk assessment process and mitigation strategies.
  • Communicate effectively with all stakeholders, including clients, to ensure a shared understanding of potential risks and risk management measures.

How Can FOCAL Help Estate Agents?

Real estate agents must adhere to Know Your Customer (KYC) requirements and conduct Customer Due Diligence (CDD) to meet Anti-Money Laundering (AML) regulations. And this can be achieved by implementing FOCAL AML compliance suite.

Due diligence in real estate helps in safeguarding the seller and buyer. Also, ensuring KYC compliance in real estate involves collecting accurate customer data and verifying their identity, emphasizing the need for continuous updates in case of information changes. The documentation includes details such as the full name, date of birth, address, and background information. Non-compliance with KYC regulations and AML laws can lead to severe consequences, including fines, license revocation, or imprisonment for real estate companies.

Real estate agents need to implement AML requirements when swiftly opening customer accounts to ensure customer satisfaction. How can they do so? By using advanced technology like FOCAL. FOCAL automates all AML control processes for organizations, spanning from customer account initiation to money transfer transactions.

FOCAL boasts a comprehensive global database including politically exposed persons (PEP), blocked individuals, and sanctions lists. The database undergoes real-time updates, enabling organizations to check their customers against it 24/7. Estate agents can follow AML rules and avoid fines by using FOCAL solutions.

Aseel, the pioneering real estate crowd-investing platform in Saudi Arabia, faced challenges in customer onboarding, risk assessment, and scalability due to manual processes. Later, Aseel chose FOCAL to automate processes and enhance compliance. Implementing FOCAL transformed Aseel's compliance procedures, reducing onboarding time by 87% to just 40 seconds and enabling swift customer onboarding. FOCAL's AI-powered technology facilitated a 250% growth, providing comprehensive risk assessment and eliminating manual efforts, false alerts, and human errors. 


In conclusion, the real estate sector is susceptible and vulnerable to money laundering, making AML checks for estate agents imperative. AML compliance for estate agents and following the rules aids in avoiding fines. Embracing advanced technologies such as FOCAL becomes a strategic move for AML checks for estate agents. FOCAL not only ensures AML compliance for estate agents but also enhances the efficiency of the process. 


Q1. How to Detect Suspicious Transactions in Real Estate?

To prevent money laundering effectively, estate agents must recognize unusual patterns related to:

Q2. Why is it important for estate agents to file a Suspicious Activity Report (SAR)?

Filing a Suspicious Activity Report (SAR) is crucial for estate agents as it helps prevent money laundering and terrorist financing when there is reasonable suspicion of buyers. Failure to promptly submit a SAR may result in regulatory penalties.

Q3. What are the KYC requirements for estate agents?

KYC requirements for estate agents involve implementing control procedures to identify and mitigate risks associated with illegal financial activities such as money laundering, terrorist financing, corruption, and fraud. 

The process includes collecting accurate customer information, determining the customer's risk level through Due Diligence procedures, and developing a control program tailored to the risk level. This aligns with European Union Directives (EU) and Financial Action Task Force (FATF) proposals and ensures compliance.

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