AMLR: new rules in 2027, responsibilities today
Imagine a Tuesday in autumn 2027. Your national supervisor asks for your agency's risk assessment, its internal AML procedures and the records showing how you checked the parties to your last ten property transactions. Could your team retrieve the information and explain the decisions, without searching through individual inboxes?
For real estate businesses, the EU Anti-Money Laundering Regulation is not the arrival of AML obligations in a previously unregulated sector. Estate agents are already covered by the existing EU framework and its national implementing laws. The change is a directly applicable, more harmonised rulebook, generally applying from 10 July 2027.
Key points
Real estate agents already have AML responsibilities; 2027 is not permission to postpone them.
AMLR brings common EU requirements, while national supervision and certain national rules remain relevant.
Readiness means a working system of risk assessment, due diligence, reporting, controls and evidence.
What changes, and what does not
Regulation (EU) 2024/1624 moves core obligations into a regulation that applies directly across EU Member States. Agencies should therefore compare their existing arrangements with the new requirements rather than assume that everything starts from zero. A business with established procedures has a foundation to build on. A business relying mainly on passport copies has a wider task.
The practical question is whether the process works from beginning to end. Can staff recognise a concern, obtain appropriate information, reach the right decision-maker and record the outcome? A policy that describes those steps is useful only when the agency actually follows it.
Which real estate activities are covered?
AMLR covers estate agents and other real estate professionals to the extent that they act as intermediaries in property transactions. It also covers letting intermediation where the monthly rent is at least EUR 10,000 or its equivalent. That rental threshold must not be mistaken for an exemption for property sales.
Start with the activities your business actually performs: residential sales, commercial transactions, relevant lettings, buyer representation and work through branches or agents. Do not assume that every property-related activity has identical treatment, or that a job title determines the answer. Identify the applicable obligations and the competent supervisor in each jurisdiction where you operate. [1]
This is an EU framework, not a rule automatically applying to every country in Europe. Within the EU, national reporting channels, supervisory instructions and additional rules permitted by the legislation still need attention. A common rulebook does not eliminate the need to understand the local operating environment.
Five building blocks, one connected process
First, assess your own business risks. The assessment should reflect your customers, services, locations and working methods, including exposure to money laundering, terrorist financing and the non-implementation or evasion of targeted financial sanctions.
Second, establish internal policies, responsible people, training and controls, including independent testing.
Third, organise customer due diligence and transaction assessment: identity, beneficial ownership, relevant screening, the purpose of the transaction and funding enquiries proportionate to risk.
Fourth, define how concerns reach the person responsible for assessing and reporting suspicions to the Financial Intelligence Unit.
Fifth, keep the supporting information and decisions accessible throughout the applicable retention period.
These are not five unrelated folders. A risk identified in the business assessment should influence the questions staff ask. An unexplained answer should trigger the appropriate review. The review should leave evidence of what was considered and why the agency acted as it did.
Start with your existing files
Choose a small sample of completed and live transactions. Compare the files with your written procedures. Identify missing evidence, unclear responsibilities and steps that happen too late. Assign an owner to each gap and test the revised process on new work.
A smaller agency can organise compliance proportionately; it does not need to imitate a bank. But proportionality means fitting the system to the business and its risks, not treating the requirements as optional.
Back to the hypothetical inspection: the goal is not a larger pile of documents. It is a clear explanation of how your agency manages its risks. Start building that explanation now, while there is time to improve the process.
Next week, Part 2: You may not handle the money, but you help shape the transaction. What should a real estate agency notice?