The prevention of money laundering in real estate is one of the responsibilities that certain professionals in the sector must incorporate into their business activities. Properly identifying clients, determining the beneficial owner, assessing risks and paying attention to unusual transactions are not simply administrative procedures: they form part of a system designed to prevent the real estate market from being used to introduce funds of illicit origin into the legitimate economy.

In Spain, Law 10/2010 includes real estate developers and professionals who carry out agency, commission or intermediary activities in the purchase and sale of real estate among the obliged entities. SEPBLAC also provides a catalogue of risk transactions specifically for the real estate sector.

Moreover, the regulatory landscape is changing. The new European anti-money laundering and counter-terrorist financing package establishes a more harmonised framework, with Regulation (EU) 2024/1624 — known as the AMLR — and Directive (EU) 2024/1640, together with the new Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA). Much of the new framework will apply from 10 July 2027.

For real estate professionals, the challenge is not only to understand these rules but also to have procedures in place that make it possible to apply and demonstrate the controls performed.

Why Does Anti-Money Laundering Apply to Real Estate Agencies?

The real estate sector has characteristics that require particular attention from an anti-money laundering perspective. Transactions can involve large amounts of money, natural and legal persons, corporate structures and funds from different sources.

For this reason, Spanish legislation expressly includes real estate professionals among obliged entities.

This means that a real estate agency should not regard anti-money laundering measures as an isolated check carried out at the end of a property transaction. They should be integrated into its procedures, with the appropriate measures applied according to the circumstances and risk associated with each transaction.

SEPBLAC also states that any fact or transaction which, by its nature, could be related to money laundering or terrorist financing should receive special attention from obliged entities.

Main Anti-Money Laundering Obligations for Real Estate Agencies

Although the specific measures will depend on each situation and its level of risk, there are several fundamental controls that professionals should understand.

Client Identification and Verification

One of the pillars of prevention is knowing who you are conducting a transaction with.

The real estate agency must apply the appropriate identification and verification measures, checking identity using valid documentation and keeping evidence of the actions performed.

This is not simply a matter of requesting a name and an identification document. The aim is to ensure that the client’s identity can be properly verified and that the file contains the necessary evidence.

The new European Regulation also specifies when customer due diligence becomes relevant in real estate intermediation. One of the examples it provides is the point at which the parties make and accept an offer to purchase or rent. Before there is genuine interest in proceeding with a specific property, the Regulation itself states that it would not be proportionate to apply such due diligence to every prospective client.

Identification of the Beneficial Owner

A transaction may be carried out through a company or another legal structure. In such cases, knowing only the name of the company may not be sufficient.

Identifying the beneficial owner seeks to determine which natural person ultimately owns or controls the relevant entity.

This becomes particularly important where complex corporate structures exist or several entities are involved between the purchaser and the individuals who ultimately exercise control.

The new European framework continues to treat beneficial ownership as one of the central elements of the preventive system and provides for mechanisms aimed at strengthening the information available in this area.

Risk Assessment

Not all real estate transactions present the same level of risk.

Preventive measures should make it possible to analyse factors related to the client, the transaction and other relevant circumstances. The AMLR itself includes risk variables that obliged entities will need to consider when conducting their assessments and determining the extent of due diligence required.

Therefore, the objective is not simply to tick a box confirming that the client has been identified. The agency needs to be able to connect the information collected with a consistent assessment of risk.

Where the risk is higher, enhanced due diligence measures may be required.

Source of Funds and Risk Transactions

A transaction may require particular attention when circumstances arise that are inconsistent with its nature, the client’s profile or the information available.

This is where analysing factors such as the source of funds and the economic rationale of the transaction becomes particularly important.

The catalogue published by the Commission for the Prevention of Money Laundering and Monetary Offences for the real estate sector is specifically intended to help developers and real estate intermediaries prepare their own list of risk transactions. It is not intended to constitute an exhaustive list of every possible scenario.

PEPs, Sanctions and Other Alerts

Client checks may also require determining whether circumstances exist that imply a different level of risk, including whether the person is a politically exposed person (PEP) or whether other relevant alerts exist.

Identifying a match does not automatically mean that money laundering is taking place. What matters is having procedures that make it possible to identify these circumstances, assess them correctly and apply the appropriate measures.

Record Keeping and Evidence

In anti-money laundering compliance, performing a control and being able to demonstrate that it was performed are closely related.

Files should allow the required documentation and evidence to be retained for the periods established by law. This makes it possible to reconstruct which checks were performed, what information was available and how a particular transaction was handled.

Document traceability therefore becomes an essential part of compliance.

Warning Signs in a Real Estate Transaction

There is no single warning sign that automatically establishes that a transaction is related to money laundering. The assessment must always take the context into account.

However, there are indicators that may justify special examination. SEPBLAC’s sector-specific catalogue includes various scenarios relating, among other matters, to the characteristics of the parties involved, payment methods, the characteristics of the transaction and behaviours that make it difficult to determine the true identity of the parties.

For a real estate agency, this reinforces the importance of having procedures capable of detecting inconsistencies and escalating them when necessary.

An alert should not automatically be interpreted as proof of unlawful activity either. It is an element that must be assessed within the context of the transaction and in accordance with the applicable obligations.

Training in Anti-Money Laundering

A procedure can be perfectly documented and still prove ineffective if the people responsible for applying it do not know how to recognise a risk situation.

For this reason, AML/CFT training is another important component of the preventive system.

Employees and professionals concerned need to understand what information they should request, how to follow internal procedures, which circumstances deserve special attention and how to respond to a potential alert. For this reason, training for real estate agents and the continuous updating of professional knowledge are particularly relevant.

In the materials prepared by GIPE and Iberdata21, training is one of the pillars of the compliance proposal for the real estate sector, together with identification, verification and documentation tools. GIPE also offers real estate training with a European certificate for professionals seeking to keep their knowledge and qualifications up to date.

GIPE course on anti-money laundering (8 October 2026)

GIPE has scheduled a dedicated course on the prevention of money laundering for real estate professionals, taking place on 8 October 2026. The training covers what information should be requested from the client, how to apply internal procedures, which transactions deserve special attention and how to respond to a potential alert, in line with current regulations and the new European framework that will apply from 2027.

The practical objective is for prevention to become part of everyday work rather than being limited to having documentation that nobody consults.

What Will Change Under the New European Framework in 2027?

This is one of the issues that real estate professionals should begin to take into account.

In 2024, the European Union adopted a new legislative package designed to move towards a more harmonised system for preventing money laundering and terrorist financing.

One of its pillars is Regulation (EU) 2024/1624 (AMLR). Unlike a directive, which requires transposition into national law, the Regulation will be directly applicable and, as a general rule, will apply from 10 July 2027.

The Regulation itself expressly recognises the exposure of real estate transactions to money laundering risks and includes real estate agents and other real estate professionals within its scope under the conditions established by the Regulation.

Alongside the AMLR is Directive (EU) 2024/1640, commonly referred to as the sixth Anti-Money Laundering Directive or AMLD6, which regulates mechanisms that Member States will be required to establish. The general transposition deadline is 10 July 2027, although certain provisions have specific dates.

The third relevant element is AMLA, the new European authority specialising in anti-money laundering and countering the financing of terrorism. The authority was legally established in 2024, is headquartered in Frankfurt and began operations in 2025.

For real estate agencies, 2027 should not simply be regarded as a date on the calendar. It is an opportunity to review in advance whether internal procedures, tools and training are ready for a more harmonised European regulatory environment.

From Compliance to Being Able to Demonstrate Compliance

One of the most important messages for real estate professionals is this: compliance requires evidence.

A consistent file should make it possible to reconstruct the actions carried out whenever necessary: identification and documentation, beneficial ownership where applicable, risk assessment, alerts detected, decisions made and any other applicable controls.

Digitising some of these processes can facilitate traceability, particularly when an agency manages numerous transactions simultaneously.

However, technology does not replace professional judgement, nor does it automatically make a procedure compliant with regulations. It must form part of a preventive system appropriate to the activities and circumstances of each professional or company.

GIPE and Iberdata21: Support for Anti-Money Laundering Compliance

Against this backdrop, GIPE and Iberdata21 collaborate to provide real estate professionals with tools and resources related to compliance, training and anti-money laundering measures.

According to the documentation provided for this collaboration, the proposal includes solutions for searching and verifying information relevant to AML compliance, specialised training for the real estate sector and tools related to the internal reporting channel.

For GIPE members, this collaboration also includes special conditions for certain Iberdata21 solutions. These complement other benefits available to GIPE members, such as ongoing training, advice and access to a professional network.

The aim is to make it easier for agencies to approach compliance in a more structured way, from training their professionals to carrying out and documenting specific controls.

GIPE members who are interested can contact GIPE to find out about the current terms and solutions available through the collaboration with Iberdata21. If you are not yet a member of the association, you can find out how to join GIPE.

Frequently Asked Questions About Money Laundering and Real Estate

Are Real Estate Agencies Required to Prevent Money Laundering?

Yes, in the circumstances established by the applicable legislation. Law 10/2010 includes real estate developers and professionals who carry out agency, commission or intermediary activities in the purchase and sale of real estate among obliged entities.

What Should a Real Estate Agency Check About Its Clients?

Relevant measures include identifying and verifying the client and, where applicable, identifying the beneficial owner, together with an appropriate risk assessment and any other due diligence measures required in each case.

What Is a Beneficial Owner in a Real Estate Transaction?

Put simply, it is the natural person who ultimately owns or controls an entity or legal structure. Identifying the beneficial owner helps prevent a company from acting as a layer that obscures who is actually behind a transaction.

What Happens if a Real Estate Transaction Presents Warning Signs?

A warning sign does not in itself prove the existence of money laundering. The transaction must be assessed in accordance with the applicable procedures and obligations. Regulations require particular attention to facts or transactions which, by their nature, could be related to money laundering or terrorist financing.

What Is the AMLR and When Will It Apply?

The AMLR is Regulation (EU) 2024/1624, which establishes European requirements concerning the prevention of money laundering and terrorist financing. As a general rule, it will apply from 10 July 2027.

What Is AMLA?

AMLA is the European Union’s Authority for Anti-Money Laundering and Countering the Financing of Terrorism. It was created to strengthen and coordinate the new European supervisory system in this area.

Is It Important to Keep Evidence of the Checks Performed?

Yes. Documentation and traceability make it possible to demonstrate the actions carried out and maintain a consistent record of the measures applied to a transaction.

Does GIPE Offer Training on Money Laundering?

Yes. GIPE has scheduled a dedicated course on the prevention of money laundering for real estate professionals on 8 October 2026, focused on the practical application of client identification, risk assessment and alert management obligations.

Conclusion

The prevention of money laundering in real estate should not be regarded as something separate from day-to-day business activities. For the professionals concerned, identifying clients, determining the beneficial owner where appropriate, assessing risks, examining transactions that present warning signs and retaining evidence are all part of the compliance framework.

Furthermore, 10 July 2027 will mark an important milestone with the general application of the AMLR and the development of the European AML/CFT framework.

Preparing in advance gives professionals an opportunity to review procedures, train their teams and put appropriate tools in place before that date. In this context, the collaboration between GIPE and Iberdata21 aims to provide real estate professionals with resources that can facilitate this process.