Know Your Transaction

KYT — Know Your Transaction: Compliance That Continues After Onboarding

Know Your Transaction is the often-overlooked fifth pillar of the AML framework — and its neglect is one of the most common failure modes in real estate compliance. The logic is straightforward: a customer who passes every onboarding check with flying colours may subsequently engage in transaction behaviour that is inconsistent with their stated profile, indicative of layering or placement, or otherwise suspicious. Without ongoing monitoring, that behaviour goes undetected.

Under the AMLR's Article 26, ongoing due diligence is a permanent legal obligation — not an optional enhancement. For real estate professionals, this translates into:

Transaction monitoring — reviewing payment flows, transaction timing, and counterparty relationships for patterns that deviate from the expected profile established at onboarding. Red flags include: payments received from accounts or jurisdictions inconsistent with the customer's profile; prices significantly above or below market value; rapid resale of a recently acquired property; use of multiple intermediaries or accounts with no apparent commercial rationale; and requests to split transactions or payments in ways that suggest structuring to avoid reporting thresholds.

Periodic KYC refresh — customer records, risk assessments, and screening results must be updated at intervals calibrated to risk level. A high-risk customer may require annual review; a lower-risk customer may warrant review every two or three years. But "periodic" means periodic — not "whenever it comes to mind." The AMLR requires the process to be systematic and documented.

Event-triggered reassessment — certain events require immediate reassessment regardless of when the last periodic review was conducted. These include adverse media coverage identifying the customer in new criminal or regulatory proceedings; a change in the customer's sanctions status; a significant change in the customer's beneficial ownership structure; and any transaction that generates a suspicion, however preliminary.

Suspicious Activity Reporting (SAR) — when monitoring generates a genuine suspicion of money laundering or terrorist financing, the professional is legally obligated to file a report with the national Financial Intelligence Unit (FIU) — and to do so without "tipping off" the customer. The tipping-off prohibition is a criminal liability provision: informing a customer that they are being investigated or reported is itself an offence.

The KYT failure mode in real estate is systemic: most agencies have no ongoing monitoring infrastructure at all. Transactions are treated as discrete events that begin and end at completion. The customer is onboarded, the deal closes, the file is archived — and the relationship is considered concluded from a compliance perspective. For transactional agents who genuinely have no continuing relationship with the parties, this may be partially defensible. For property managers, letting agents, and advisers who maintain ongoing relationships, it is a straightforward non-compliance.

Immosurance addresses KYT through integrated ongoing monitoring that activates automatically once a client and transaction dossier are established. The platform's connections to LexisNexis and other screening providers enable continuous rescreening — when a sanctions list update or adverse media event touches an existing client, an alert is generated in real time and routed to the compliance officer. Periodic review schedules are set automatically based on the client's risk classification and surfaced as tasks within the platform's dashboard. Audit trails capture every monitoring action, every alert reviewed, and every decision documented — ensuring that the ongoing due diligence obligation is as evidenced as the initial onboarding was.