Resources · Published 19/06/2026

AML/CFT obligations of estate agents: the clear guide

Real estate professionals are fully-fledged AML/CFT obliged entities. Here, without the jargon, is what the law expects of you — and how to make it traceable.

Estate agents, property dealers, property managers: since the anti-money-laundering framework was extended to non-financial professions, you are obliged entities under the rules on combating money laundering and terrorist financing (AML/CFT). In practical terms, this translates into five families of obligations.

1. Identify and verify your client (and the beneficial owner)

Before entering into a business relationship, you must identify the client and then verify their identity against a reliable document. Where the client is a company, you must trace the chain of ownership up to the beneficial owner — the individual or individuals who genuinely own or control the entity.

Ref. art. L.561-5 and L.561-2-2 of the Monetary and Financial Code (CMF).

2. Assess the risk (risk-based approach)

Not every transaction carries the same risk. You must rate each relationship or transaction (low, standard or enhanced risk) against objective criteria: the nature of the transaction, the source of funds, geography, the presence of a politically exposed person (PEP), the legal structure. This rating determines how intensive your due diligence must be.

3. Screen against sanctions, asset freezes and PEPs

You must check that your client and the beneficial owners do not appear on sanctions lists, asset-freeze lists or among politically exposed persons. Asset freezing applies before the transaction, without delay and whatever the amount: it is not a measure that can be scaled to the risk.

4. Keep the evidence for five years

Identification records and due diligence measures must be kept for five years after the end of the business relationship; documents relating to transactions, for five years after they are carried out. In the event of an inspection, you must be able to reconstruct the complete file.

Ref. art. L.561-12 CMF.

5. Report a suspicion, where necessary — and stay confidential

If you suspect that funds derive from an offence, you must file a suspicious activity report with the FIU. This act is strictly personal and confidential: its existence may not be disclosed to the client or to third parties, on pain of penalty.

Ref. art. L.561-15 and L.561-18 CMF.

Who supervises you?

For real estate, AML/CFT supervision is carried out by the DGCCRF; the power to impose penalties rests with the National Sanctions Commission (CNS). The sector is identified as a priority: undocumented due diligence is, in the eyes of the inspector, tantamount to due diligence not performed.

How to make all this sustainable day to day

The challenge is not merely to perform these steps, but to be able to prove them. That is precisely the role of a tool like Vigilae: the AI reads the documents and prepares the file, a deterministic engine rates the risk and runs the screening, and you decide. At the end, a time-stamped evidence file is ready to present — without the tool ever deciding or reporting on your behalf.

This article is for information only and does not constitute legal advice. It reflects the state of the law as at its publication date (June 2026). For your own situation, consult your compliance officer or a specialist lawyer.

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