Real estate firmsunder the new EU AML rules
Estate agents are obliged entities under the AMLR, including when they act as intermediaries in lettings with a monthly rent of EUR 10,000 or more. Mortgage brokering, property crowdfunding and company formation can bring further services into scope.
- The AMLR applies from 10 July 2027
- Client due diligence, screening and records in one platform
- Hosted in the EU
Which real estate services are covered
The AMLR names estate agents, including when they act as intermediaries in the letting of immovable property for transactions with a monthly rent of EUR 10,000 or more. Several services that real estate firms often offer alongside brokerage are covered by their own provisions.
- Brokerage of property sales and purchases
- Letting with a monthly rent of EUR 10,000 or more
- Brokering mortgage or consumer credit as a credit intermediary (Article 3(3)(k))
- Crowdfunding of property projects (Article 3(3)(h))
- Intermediation for residence-by-investment schemes (Article 3(3)(l))
Also covered: company and trust services
A firm that provides any of the following services to clients is also a trust or company service provider under the AMLR, whatever its main profession.
- Formation of companies or other legal persons
- Acting as, or arranging for someone to act as, director, secretary or partner of a company or partnership
- Providing a registered office, business, correspondence or administrative address
- Acting as, or arranging for someone to act as, trustee of an express trust or nominee shareholder
Four areas to prepare before 10 July 2027
The AMLR sets the same requirements for every obliged entity. The effort differs with the size of the firm and its clients.
Governance
- Name a compliance manager at management level
- Appoint a compliance officer
- Set up oversight and reporting to management
Customer due diligence
- Risk-based due diligence on clients and beneficial owners
- Record the risk rating and review it
- Apply group-wide procedures where the firm is part of a group
Records and reporting
- Keep the firm-wide risk assessment up to date
- Keep due diligence records for five years
- Report suspicious transactions to the national FIU
Processes
- Standardise onboarding and review steps
- Replace manual look-ups with automated checks
- Keep one audit trail per client
Due diligence reports for company clients
Incmply retrieves publicly available information on company clients, including beneficial owners, directors and financial information, and builds the due diligence report your procedure requires.
Incmply Checks and Credits
Incmply is priced on individual case files, company case files and the number of users. Compliance checks are paid for with Incmply Credits, so your firm uses exactly the checks it needs.
One-time sanction check
Verifies whether individuals or companies appear on sanctions lists.
Adverse media check
Scans for negative media coverage of individuals and companies.
Ongoing daily sanction check
Continuous monitoring of higher-risk entities against sanctions lists.
Daily adverse media check
Daily scans for new adverse media mentions.
Company structure check
Identifies and verifies beneficial owners across additional layers of ownership.
One-off checks
Individual checks on persons or companies without opening a case file.
The AMLR applies from 10 July 2027
The regulation applies directly in every member state. Firms should have the following in place by that date.
- A firm-wide risk assessment
- Customer due diligence, standard and enhanced
- Compliance functions named and in place
- Internal policies, procedures and controls
- Record-keeping and retention
How ready is your firm?
Ten short questions on how your firm handles client due diligence today. The first question is about your sector; the rest are the same for every obliged entity. You receive the result and a guide by email.
Does the AMLR apply to the work your firm does?
Tick the services your firm provides.
Your firm's AI-generated onboarding report
Enter your firm's details and Incmply generates an initial onboarding report from publicly available information.
You should receive your report 5 to 10 minutes after submission.