A passport upload is not the end of customer due diligence

AMLR for Real Estate — Part 3 of 5

A prospective buyer contacts your agency online on Sunday evening.

They upload a passport image, explain that a company will purchase the property and ask to pay a reservation deposit on Wednesday.

You have never met the buyer. The seller wants to move quickly.

Who needs checking, and when?

This is where modern real estate processes and AML obligations meet.

For a real estate agency, receiving a copy of an identity document is only the beginning. The process also needs to establish who the person really is, whether they are acting for themselves or for a company, who ultimately owns or controls that company, whether relevant screening produces concerns and whether the agency has enough information to proceed.

Under AMLR, real estate customer due diligence concerns both parties to the property transaction, not simply the person paying the agency’s commission.

Three points to remember

• Build your process around both sides of the transaction.

• Define clear verification checkpoints before funds or property move.

• Technology can support identification and screening, but your agency remains responsible for its assessment and decisions.

Collecting identity information is not the same as verifying identity

A passport image tells you what someone claims their identity to be.

That does not automatically establish that the document is genuine, that it belongs to the person using it or that the person has the authority to act in the transaction.

For an individual, your process must therefore distinguish between collecting identity information and verifying it.

Where someone acts on behalf of another person or company, the process also needs to address their authority to do so.

And when the buyer is a company, stopping at the person who signs the reservation form is not enough.

The agency needs to identify the legal entity and investigate the relevant beneficial owners behind it.

This is particularly important in real estate, where the person attending a viewing, negotiating the price, signing documents and ultimately funding or owning the property may not always be the same person.

The objective is not to make every transaction unnecessarily complicated.

It is to establish that the people and entities involved are who they say they are—and that you understand who ultimately stands behind the transaction.

Beneficial ownership: look beyond the signatory

Imagine the buyer tells you:

“The property will be purchased by our company.”

The next question is not simply whether the company exists.

Who owns or controls it?

Under AMLR, corporate beneficial ownership includes natural persons who own 25% or more of the entity or who exercise control through other means.

That means the process must be able to move beyond the company name and identify the relevant natural persons behind it.

Complexity alone does not mean something is wrong.

A legitimate business may have several shareholders, holding companies or cross-border ownership arrangements.

But complexity should not become an excuse for stopping the assessment too early.

The agency needs enough information to understand who ultimately owns or controls the customer and to resolve gaps or inconsistencies where necessary.

Timing matters in a real estate transaction

Real estate has its own operational rhythm.

A potential buyer may first browse listings, then request a viewing, make an offer, negotiate conditions and eventually reach an accepted offer.

Those stages do not all create the same AML situation.

AMLR introduces a specific timing rule for real estate agents: identity verification is carried out after an offer has been accepted by the seller or lessor and, in all cases, before funds or property are transferred. Until AMLR applies, agencies must continue following the national requirements currently applicable to them.

That timing needs to be translated into your actual sales process.

Returning to our Sunday-evening buyer: a proposed reservation payment on Wednesday should not bypass the appropriate verification checkpoint simply because final completion may still be weeks away.

At the same time, someone casually browsing property listings is not necessarily at the same stage as a buyer whose offer has been accepted.

The challenge is to define the checkpoint clearly enough that staff know when the process must be complete.

If the rule exists only in the AML manual but nobody knows where it fits into the sales workflow, it is not yet an operational process.

Online identification changes the method—not the responsibility

Real estate transactions increasingly begin remotely.

Customers may enquire through a website, send documents by email, join a video call and make an offer without ever entering the agency’s office.

AMLR recognises electronic identification and reliable independent sources as possible parts of the verification process, including qualifying electronic identification and trust services.

Technology therefore becomes extremely useful.

It can help verify identity, screen names and organise records far more consistently than an informal email-based process.

But the presence of technology does not transfer responsibility away from the agency.

A green result on a screen does not automatically answer every question about the customer.

Your agency still needs a process for deciding what the result means.

Screening is only useful if you know what happens next

Identity verification is one part of customer due diligence.

Relevant screening can raise other questions.

What happens if the person may be politically exposed?

What happens if a sanctions screening result produces a possible match?

What happens if the company structure identifies a beneficial owner who was never mentioned during the initial contact?

A robust process cannot end with:

“The system returned a hit.”

Someone needs to assess the result.

Is it genuinely the same person, or simply someone with a similar name?

Does additional information resolve the concern?

Does the case require further review or escalation?

Who makes that decision?

And where is the reasoning recorded?

This distinction is important because screening technology supplies information; the agency must still interpret and act on it.

Both sides of the property transaction matter

One practical change agencies should prepare for is making sure the AML workflow is not designed solely around the person who pays the commission or appears to be the agency’s direct customer.

The transaction may involve:

• an individual seller,

• an individual buyer,

• a corporate purchaser,

• representatives acting under authority,

• beneficial owners behind legal entities,

• and other people relevant to the transaction structure.

AMLR’s real-estate approach means due diligence needs to take account of both sides of the transaction.

That has practical consequences for CRM workflows, document collection, screening and transaction records.

If your current process only creates an AML file for one side, now is the time to review how that will work under the new framework.

Make the process repeatable

Return to the Sunday-night enquiry.

A strong process should allow your team to answer:

Who is the buyer?

Has identity been properly verified?

Who is behind the company?

Have the relevant beneficial owners been established?

Who is acting?

If someone represents the buyer, has their authority been checked?

What did screening show?

Were possible PEP or sanctions results assessed rather than simply stored?

When must the checks be completed?

Is the verification checkpoint built into the transaction workflow?

Who makes the decision when something does not add up?

And finally:

Can you show later what was checked, what was found and why the agency proceeded?

The purpose is not to slow down every transaction.

It is to make sure that speed does not replace control.

From scattered checks to one connected process

For many agencies, the biggest challenge is not performing an identity check.

It is connecting all the information.

A passport is stored in one place.

The company documents are somewhere else.

A screening result sits in another system.

A colleague knows who the beneficial owner is.

The sales agent remembers why the buyer changed.

That may work until someone needs to reconstruct the file.

AMLR readiness means creating a process where those elements form one understandable transaction record.

Identity. Beneficial ownership. Screening. Risk assessment. Decision. Evidence.

That is where a real-estate-specific compliance platform such as Immosurance can turn individual checks into a connected workflow.

Technology should make the process easier to follow and easier to prove—not replace the professional judgement behind it.

Before Wednesday arrives

The online buyer in our example wants to make a reservation payment in only a few days.

That is exactly why the process should be designed beforehand.

Not when the seller is waiting.

Not when the customer is asking why the transaction is delayed.

And not when an employee has to decide, under pressure, what checks are still missing.

Define the process now.

Know who needs checking.

Know when verification must happen.

Know how beneficial ownership is established.

Know what happens when screening produces a result.

And make sure the decision can be reconstructed afterwards.

A passport upload is not the end of customer due diligence. It is the beginning of understanding who is really behind the transaction.

Start building that process now—with Immosurance.

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Coming next — Part 4

Who is responsible, including in sales?

In Part 4, we look at management responsibility, internal roles, training, controls and what happens when external or self-employed sales agents form part of your real estate organisation.