AMLA Finalises Key Standards
AMLA Finalises Key Standards for the Private Sector: What This Means for Real Estate Professionals
On 1 October 2026, AMLA finalised three sets of draft Regulatory Technical Standards (RTS) that make the future EU AML framework much more concrete for the private sector. These standards define key measures companies and professionals must apply to reduce money laundering and terrorist financing risks, and they form an important step toward a clearer and more consistent EU AML/CFT rulebook. AML/CFT Authority
For the real estate sector, this is more than a technical update. It is a signal that AMLR preparation is moving from legal theory into operational reality.
Real estate agencies, developers, franchisors, networks, property-related service providers and mortgage credit intermediaries will increasingly need to prove that their AML processes are structured, risk-based, documented and consistent. The days of informal checks, fragmented records and “we know our client” explanations are coming to an end.
What AMLA Has Finalised
AMLA has finalised three sets of standards for the private sector.
The first concerns business relationships, occasional transactions and linked transactions. It explains how companies and professionals should distinguish between these categories, and how linked transactions should be identified so that Customer Due Diligence thresholds are applied consistently.
The second concerns Customer Due Diligence. It specifies the information companies and professionals must collect and verify, including proportionate measures for lower-risk situations, non-face-to-face verification, electronic identification, and screening of politically exposed persons, their family members and close associates.
The third concerns group-wide arrangements. It sets minimum requirements for effective group-wide AML/CFT arrangements, including governance, risk management, internal controls and secure information sharing.
Together, these standards give obliged entities and supervisors clearer expectations on how the new AML rules should be applied in practice. AMLA states that the aim is to strengthen AML/CFT controls and improve financial crime prevention and detection, while remaining proportionate and risk-based.
Important: These Standards Are Not Yet the Final Legal Text
The final draft standards have been submitted to the European Commission. Once adopted and published in the Official Journal of the European Union, they are proposed to apply six months after their entry into force. For football agents and professional football clubs, AMLA states that they will apply from 10 July 2029. y
This means businesses should not treat the standards as optional reading. They show the direction of travel and the level of operational detail that AMLR compliance will require.
1. Business Relationships, Occasional Transactions and Linked Transactions
One of the most practical issues for real estate professionals is knowing when AML obligations are triggered.
AMLA’s factsheet on the Article 19(9) RTS explains that before applying Customer Due Diligence, an obliged entity must determine whether the customer engagement is a business relationship or an occasional transaction. A business relationship requires CDD and ongoing monitoring. An occasional transaction below the relevant threshold does not require CDD unless one of the AMLR exceptions applies, while an occasional transaction at or above the relevant threshold usually requires CDD.
This matters in real estate because professionals do not always carry out the financial transaction themselves. AMLA makes clear that for service providers that do not carry out transactions themselves, the value of the underlying asset or transaction — not the fee charged for the service — is used when determining whether the relevant threshold has been met.
For real estate agents, lawyers and other professional service providers, AMLA highlights two practical criteria: whether the service is expected to extend over time, and the expected number of services provided to the customer.
This is highly relevant for real estate businesses that maintain ongoing client relationships, manage repeated transactions, work with investors, handle portfolios, or operate in high-value markets.
2. Linked Transactions: Why Splitting Does Not Remove Risk
AMLA’s standards also clarify how linked transactions should be identified.
Two or more occasional transactions may be linked where they have the same or similar origin, destination and purpose, or other common characteristics. They can also be linked when carried out by the same customer or by multiple customers operating in concert. Where occasional transactions are linked, the relevant threshold must be assessed based on their combined value.
For real estate, this is essential. Criminal behaviour is often structured to make individual actions look harmless. Multiple payments, several parties, staged transactions, related buyers or repeated dealings may each look acceptable in isolation. AML compliance requires professionals to look at the pattern.
This is where technology becomes critical. A real estate AML platform should not only collect documents; it should help identify whether transactions, clients, funding sources or counterparties are connected.
3. Customer Due Diligence Becomes More Standardised
AMLA’s RTS on Customer Due Diligence specifies the information obliged entities must collect and verify. The AMLR requires obliged entities to identify and verify customers, persons acting on behalf of customers, natural persons on whose behalf or for whose benefit a transaction or activity is being conducted, and beneficial owners before establishing a business relationship or carrying out an occasional transaction.
The standards specify information to be collected for natural persons, legal entities, addresses, nationalities, and other core identification points. For natural persons, AMLA indicates that obliged entities should obtain all names appearing on an identity document, passport or equivalent, and that place of birth should include at least the country and the relevant local place such as state, city, municipality, town or village.
In lower-risk situations, the standards allow a reduced set of identification data for natural persons. AMLA’s factsheet explains that this reduced set includes core identity data such as names, date and place of birth and nationality, and that the address is not required in those lower-risk circumstances.
The important point is not that every file will require the same depth of information. The important point is that every decision must be proportionate, risk-based and documented.
4. Beneficial Ownership: Registers Alone Are Not Enough
Beneficial ownership remains one of the most important AML issues in real estate.
AMLA’s CDD factsheet explains that obliged entities may use sources such as public registers, business registers, residence registers, tax registers, land registers, reputable data service providers, financial institutions, other obliged entities within the same group and legal entity documents where the beneficial owner is named.
However, AMLA also makes a critical point: in low-risk situations, information from a central beneficial ownership register may be used to identify the beneficial owner, but information from the register alone is not sufficient to fulfil verification requirements. The obliged entity should verify that information using information obtained from the customer or other reliable sources.
For real estate professionals, this is a major operational message. Seeing a name in a register is not the same as understanding ownership and control. Layered corporate structures, nominee arrangements and cross-border entities require structured verification and clear documentation.
5. Non-Face-to-Face Verification and Electronic Identification
The real estate sector increasingly operates digitally. Buyers, sellers, investors and intermediaries may be located in different countries, and onboarding may happen remotely.
AMLA’s CDD standards address non-face-to-face verification and electronic identification. The factsheet explains that where an identity document, passport or equivalent cannot be submitted face-to-face and the person cannot use electronic identification means or qualified trust services, obliged entities may use alternative verification solutions, provided they rely on reliable and independent information sources and include the safeguards set out in the RTS.
This is important for cross-border real estate transactions. Remote onboarding can be allowed, but it must be controlled, reliable and properly evidenced.
6. PEP and Sanctions Screening: More Than a Checkbox
AMLA’s factsheet confirms that, as part of Customer Due Diligence, obliged entities must verify whether the customer and beneficial owners are subject to targeted financial sanctions. They must also determine whether the customer, beneficial owner, and where relevant the person on whose behalf or for whose benefit a transaction is being carried out, is a politically exposed person, a family member, or a close associate.
The factsheet also notes that screening may be performed through automated screening tools, manual checks or a combination of both, and that aliases, trade names and digital wallet addresses may be relevant for targeted financial sanctions screening where applicable and available.
For real estate businesses, this means screening cannot be treated as a one-time formality. It must be integrated into the workflow, connected to beneficial ownership, and documented in the transaction file.
7. Existing Clients Will Also Need Remediation
AMLA’s CDD factsheet addresses transitional treatment for existing and ongoing business relationships. It states that customer documentation, information and data for customers whose business relationship was established before the RTS entry into force must be brought into compliance on a risk-sensitive basis, and no later than one year for higher-risk customers and five years for all other customers, as set out in the AMLR.
This is especially important for established real estate businesses with historic client files, investor relationships, property management clients, rental portfolios or repeated buyers.
AMLR preparation is not only about new onboarding. It is also about reviewing what already exists.
8. Group-Wide Requirements: Franchises and Networks Should Pay Attention
AMLA’s group-wide standards are particularly relevant for real estate networks and franchise structures.
The factsheet states that the RTS apply to groups as defined in the AMLR and to certain structures such as networks, partnerships and franchises with common ownership, management or compliance control. It also states that they generally do not apply to stand-alone obliged entities or arrangements without common ownership, management or compliance control, such as customer referral arrangements, shared branding arrangements, shared technical platforms or other cooperation arrangements.
Where a structure is in scope, the group-wide framework must include governance and compliance oversight, a group-wide ML/TF risk assessment, AML/CFT policies and procedures applied consistently, information-sharing arrangements, staff training and reporting mechanisms, and processes to address compliance deficiencies.
For real estate franchise networks, this could be one of the most important parts of the new AML framework. A franchise model can no longer assume that compliance is purely a local office issue if common ownership, management or compliance control exists.
9. Information Sharing Inside Groups Must Be Secure and Documented
AMLA’s group-wide factsheet states that entities within a group must exchange information necessary to identify, assess and manage ML/TF and sanctions-related risks. Examples include customer and beneficial ownership information, CDD information, transaction information and risk assessment findings.
But this is not unrestricted sharing. AMLA states that information sharing must follow a need-to-know principle, comply with data protection requirements, take place through secure channels and be appropriately documented.
This is where real estate compliance must be designed carefully. Shared information can improve consistency, but every entity still needs the ability to evidence its own assessment, decisions and responsibilities.
10. Third-Country Legal Impediments: Cross-Border Groups Need a Plan
For groups with branches or subsidiaries in third countries, AMLA’s factsheet on legal impediments explains what must happen when third-country laws prevent or restrict compliance with AMLR or group-wide AML/CFT policies and controls. These impediments may affect CDD, risk assessments, information sharing, suspicious transaction report-related information sharing, supervisor information sharing and record keeping.
Where legal impediments exist, the obliged entity or parent undertaking should notify the supervisor, seek customer consent where legally possible, apply additional risk-mitigation measures, take further action where risks remain, and inform the supervisor of the measures taken.
This is relevant for cross-border real estate groups, international franchises and investment structures operating inside and outside the EU.
What This Means for Real Estate Businesses
AMLA’s finalised standards confirm a clear direction: AMLR compliance will be practical, detailed and evidence-driven.
Real estate businesses should prepare now by focusing on seven areas:
Define when each client engagement is a business relationship, occasional transaction or linked transaction.
Standardise Customer Due Diligence for buyers, sellers, tenants, landlords, investors and legal entities.
Verify beneficial ownership using reliable sources, not registers alone.
Integrate PEP, sanctions and targeted financial sanctions screening into the workflow.
Document the purpose and intended nature of relationships and transactions.
Prepare group-wide AML frameworks for networks, franchises and multi-office structures where relevant.
Review historic files and remediate existing relationships on a risk-sensitive basis.
This is exactly the type of operational challenge Immosurance was built to solve.
Immosurance: Built for AMLR-Ready Real Estate Compliance
Immosurance helps real estate professionals move from informal compliance to structured, documented and audit-ready AML workflows.
For real estate agencies, developers, networks, franchisors and related professionals, the platform supports the key pillars that AMLA’s standards make increasingly concrete:
Know Your Business risk self-assessment
Customer Due Diligence
Beneficial ownership verification
PEP and sanctions screening
Transaction risk assessment
Linked transaction awareness
Group and network compliance support
Training and certification
Audit-ready documentation
AMLR is no longer a distant legal change. AMLA’s finalised standards show what the private sector will be expected to organise, document and prove.
The businesses that start now will have time to prepare properly. Those that wait will face the same obligations, but with less time, fewer available experts and more operational pressure.
AMLR readiness starts with structure. Real estate businesses should build it now.