The real estate market and legal escrows are among the most vulnerable areas for money laundering. Regulators are well aware of this, which is why enforcement is tightening continuously for 2026. Read about what you need to prepare for as a broker or lawyer.
Table of contents
1. Are you a real estate broker terrified by AML?
A real estate intermediary becomes an obliged entity under the AML Act during the purchase and sale of real estate, and often during lease agreements exceeding certain rent limits. Changes for 2026 pressure agencies to intimately know their client long before a reservation agreement is signed.
AML training shouldn't just be an “on paper” exercise. It needs to be functional training outlining exactly what “red flags” to look for (e.g., payments from offshore accounts, obscuring ultimate beneficial owners through complex multi-national structures).
2. Lawyers, Notaries, and Escrow Accounts
In money laundering schemes involving real estate, lawyers and law firms serve as the critical first filters (so-called gatekeepers). If you handle legal escrows, you must know with absolute certainty where the funds originate from.
- Conducting detailed PEP (Politically Exposed Person) and international sanctions screenings (EU and US).
- Gathering corroborating documents – a simple ID is no longer sufficient. An AML questionnaire focusing on the Source of Wealth is mandated.
- If you harbor any suspicions (and file a Suspicious Activity Report), you must act accordingly. Failing to do so risks loss of professional licenses and crippling fines from the FAU.
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3. What should an AML Questionnaire template for brokers contain?
Before brokering a sale, the client should complete an AML questionnaire tailored for real estate agencies. In it, they must declare that the funds deployed for the real estate purchase originate from legitimate sources (salary, gifts, sale of other property, mortgage).
Another critical piece is unwrapping Ultimate Beneficial Owners (UBO). If an LLC is buying the property controlled by a foreign holding structure, the broker and lawyer have an imperative duty to trace who the final beneficiary is.
4. Avoid Unnecessary Fines from Regulators
Inspections from the Ministry of Finance (or FAU) focus primarily on the existence of functional internal processes (SVZ), tangible proof that workforce training occurred, and documented history of client screening.
Therefore, we recommend evidencing all communications, including AML questionnaires, on a centralized compliance cloud. AML PROOF offers a dedicated platform developed precisely for this purpose – far safer than scattered emails.