You do not need to handle the money to understand the risk
A €480,000 property purchase. A €150,000 private loan. Your agency never receives the purchase money. Is the funding therefore someone else’s concern?
Imagine a couple buying an apartment. They explain that €150,000 will come from a private loan from an acquaintance, with the remaining amount financed by a bank.
The property has been found, negotiations are progressing and everyone wants to move forward.
For your agency, the question is not simply whether the buyers can pay. It is whether the people, property, funding and explanation fit together. Not handling the purchase money does not remove your agency’s AML responsibilities.
Three points to keep in mind
Your perspective is different from the bank’s—but it matters.
Your business risk assessment should shape the checks used in real transactions.
An inconsistency calls for assessment, not an automatic accusation.
A different perspective from the bank
Your agency may know how the property was marketed, how negotiations developed, who attended viewings and when the proposed purchaser changed. Those observations can help explain a transaction even when you cannot see the customer’s bank activity.
However, a real estate agent should not assume that they have the complete financial picture available to a mortgage intermediary preparing a financing application. Your process needs to identify the information relevant to your agency’s role and address gaps through appropriate questions and evidence.
The objective is not to reproduce the bank’s entire lending file. It is to understand the transaction.
A useful question for your team is: “Does the explanation still make sense when we consider everything we know about this purchase?”
Assess the business before assessing the deal
The starting point is your Business-Wide Risk Assessment—BWRA.
Under AMLR, this covers exposure to money laundering, terrorist financing and the non-implementation or evasion of targeted financial sanctions. It should reflect the business’s customers, services, geographical exposure, transactions and working methods. The assessment must be documented and kept current, subject to a limited exception that supervisors may determine for individual documented assessments.
Consider two hypothetical agencies: one primarily handles local residential purchases; another regularly works on corporate acquisitions for remote international investors.
An identical set of procedures may not fit both. Neither description determines every customer’s risk, but each helps identify what the agency’s controls need to address.
Management should translate that assessment into practical instructions: what information staff need, what triggers additional checks and who resolves difficult cases. A new service or market should prompt a risk assessment before the change—not as an afterthought.
Turn inconsistencies into useful questions
An unexplained change of purchaser, an unexpected third-party payer or funding that does not fit the information available may warrant closer examination. These are prompts for assessment, not proof of money laundering. Return to the couple and their €150,000 private loan.
A private loan is not inherently suspicious. Relevant questions may include who the lender is, how they are connected to the buyers, what the loan terms are and where the lender’s funds originated.
A loan agreement may explain the arrangement. It does not necessarily explain the origin of the money.
Similarly, a bank balance may show that funds are available without explaining how they were obtained. Match the evidence requested to the question that remains unresolved.
The depth of enquiry should reflect the risk. Where higher risk or specific legal requirements call for enhanced due diligence, those additional measures must address the relevant risks.
Make the process repeatable
Whether an inconsistency receives attention should not depend solely on which employee handles the transaction.
Define what information is normally required, what triggers further enquiry and when a concern must be escalated. Record the explanation received, the evidence considered and the conclusion reached. Apply consistent rules while allowing different measures for different risks.
A shared transaction record can connect those elements and make changes visible to the people who need to act. The aim is not to collect more information indiscriminately. It is to make the assessment understandable and repeatable.
Ask your team to walk through one file: can they explain the concern, the response and the decision without relying on someone’s memory?
Before the next deal moves on
The couple’s case should end with a supported assessment—not an assumption that the bank has dealt with everything.
Use this scenario to test your procedures now. Can your team identify the unanswered questions, request relevant evidence and involve the right person?
AMLR generally applies from 10 July 2027. Use the preparation period to make your process work in practice, rather than waiting for a time-sensitive sale to expose its gaps.
Understand the transaction. Follow up the inconsistencies. Record the decision.
Start building a connected AML process with Immosurance.
----------------------------
Coming next — Part 3: Who are the people behind the transaction? Online identification, beneficial ownership and screening results.