Table of contents
- AML in real estate is not a short episode — it's a long-term trend
- Who is an obliged entity in real estate today
- AML obligations today: focus on systems and evidence
- Sanctions and supervision: the reality of recent years
- Why AML after 2025 is mainly about risk management
- How to do it without unnecessary admin
AML in real estate is not a short episode — it's a long-term trend
AML obligations in the real-estate market are not a short-lived episode, but a long-term trend that has been refined and strengthened in recent years. The key AML Act amendment in 2021 set the baseline, but the real impact became visible in the years that followed — especially due to EU AML policy and growing supervisory scrutiny.
In practice, this means one thing: it's not enough to have a policy document on file. Obliged entities must be able to prove that AML processes work in reality — and that specific steps were performed correctly for specific cases.
Real estate intermediaries are obliged entities under § 2 of Act No. 253/2008 Coll. and are among the most frequently inspected groups in the non-financial sector. The FAU focuses in particular on client identification when mediating the purchase and sale of real estate, verification of the beneficial owner for legal entities, and screening clients against sanctions lists and PEP registers.
Who is an obliged entity in real estate today
As a rule, an obliged entity is anyone who, in the course of business, performs real-estate related activities that can be misused for laundering proceeds of crime.
In practice, AML obligations typically apply to:
- real-estate intermediaries (sales and selected rentals)
- developers and real-estate investors
- entities buying and selling real estate as a business activity
- intermediaries of office, warehouse and other commercial leases
- service and group companies acting as intermediaries in real-estate transactions
A key obligation of a real estate agent is to identify the beneficial owner of every legal entity entering into a business relationship and to verify them in the beneficial ownership register pursuant to Act No. 37/2021 Coll. Failure to fulfil this obligation is one of the most frequent findings by the FAU during inspections of real estate agencies.
Real estate agents must also assess the source of funds for transactions where there is a suspicion of money laundering — particularly for cash payments, clients from high-risk countries, or PEP persons. For these clients, the law requires enhanced identification and customer due diligence (Section 9a) under § 13 of Act No. 253/2008 Coll.
AML obligations today: focus on systems and evidence
After 2025 it's clear that AML is not a paper formality. Inspections focus on whether the obliged entity has a functional, provable system in place.
- a working internal AML system — not just a generic document
- an up-to-date risk assessment aligned with the real business model
- verifiable customer identification and control
- provable training of employees and persons in a comparable position
- clearly assigned designated person
The internal policies system of a real estate agency must be tailored to the specific risks of the sector — high transaction values, anonymous buyers, clients from abroad. A generic template downloaded from the internet will not hold up. The FAU assesses the relevance of the IPS for the specific line of business.
Sanctions and supervision: the reality of recent years
Supervision by the Czech FAÚ and other authorities has tightened significantly. Sanctions remain high and are being imposed in practice.
Risk is no longer only suspicious deals, but also:
- missing or outdated documentation
- formal AML solutions with no link to practice
- mismatch between declared procedures and reality
Repeated or serious breaches can result not only in high fines, but also restrictions or bans on activity.
Why AML after 2025 is mainly about risk management
The current AML approach emphasizes the risk-based approach — managing risk based on the client, transaction and business model. Universal templates stop working.
A risk-based approach in practice means categorising clients into risk groups (low, medium, high risk) and adjusting the intensity of due diligence based on the outcome of the assessment. Standard standard identification and customer due diligence (Section 9) is sufficient for low-risk clients; enhanced identification and customer due diligence (Section 9a) is mandatory for high-risk clients. This categorisation must be documented and defensible during an inspection.
- understand their own risk profile
- work with AML continuously
- use a system that scales with their business
It's a long-term setup, not a one-off document.
How to do it without unnecessary admin
AML PROOF was created as a response to recent reality: a broader scope of obliged entities, higher proof requirements, and pressure for efficiency and clarity.
The goal isn't to “tick AML on paper”, but to have a functional, clear and controllable solution that stands up in inspections in 2025 and beyond.
AML PROOF automates client identification and screening, risk assessment, and document generation. A real estate agent or agency gets a clear system where every case — from client onboarding to archiving — leaves an audit trail with timestamps ready for the FAU. Pricing starts at 99 CZK per credit, credits with no expiry.