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.
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
For leases and similar relationships, the financial threshold (EUR 10,000 per month) remains relevant when assessing whether AML obligations apply.
What matters is not the label of the activity, but the real economic role in the transaction — a common source of mistakes during inspections.
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 employee training
- clearly assigned designated person
Crucially, each step must be traceable. It's not enough to claim the process exists — it must be auditable.
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.
Obliged entities need to:
- 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.
If you want real-estate AML processes under control without unnecessary admin, start with AML PROOF.