Question 1

Why is real estate considered high-risk for money laundering?

Accepted Answer

Real estate combines high transaction values, opacity of beneficial ownership, ease of cross-border ownership, illiquid pricing benchmarks, and historically light AML supervision of conveyancers and agents. FATF, FinCEN, and the UK NCA have repeatedly identified residential and commercial propert...

Question 2

Are real-estate agents AML-regulated?

Accepted Answer

In the UK and EU — yes, since AMLD4 / MLRs 2017, both estate agents and (more recently) letting agents above a rent threshold. In Australia — not yet; real-estate agents are scheduled to come into scope on 1 July 2026 under tranche 2. In the United States — no general federal AML obligation on ag...

Question 3

What is the FinCEN Residential Real Estate Rule?

Accepted Answer

A FinCEN reporting rule finalised in August 2024 and effective 1 December 2025 that requires designated reporting persons in non-financed residential real-estate sales to report transferee, beneficial-owner, and transaction information for sales to entities and trusts. It replaces the earlier cou...

Question 4

What screening matters most in real-estate transactions?

Accepted Answer

Buyer and seller identity and UBO; sanctions and PEP screening of all parties; source of funds documentation (especially for cash purchases); checks on related parties (lawyers, agents, lenders) where unusual; verification of the chain of payments and the bank account into which funds are release...