01
Identified
Mandate
The mandate creates the business relationship. The seller is identified and verified before the listing, not after the offer.
SellerTwo parties, one property,
a single audit trail.
A real estate agent is an obliged entity from the mandate on, not only at the signature. Seller, buyer, source of funds: AML Company gathers the diligence of the whole transaction into one file.
Check a party to the transaction
Seller and buyerSource of fundsSanctions and PEPsAudit trail
Transaction in progress
Apartment · Brussels 1050
Selling party
Marie Delcourt
Buying party
Novara Invest SRL
Price
395k €
Own funds
95k €
Loan
300k €
Preliminary contract
12/06
Where do the funds come from?
Mortgage loan300 000 €
Personal contribution95 000 €
Diligence verdictMedium
The thread of a transaction
Diligence starts at the mandate, not at the notary's
Four moments, four distinct duties. Missing the first forces you to catch up on the other three in a rush, the day before the signature.
02
In progress
Offer and preliminary contract
The buyer enters the file as soon as the offer is accepted: identity, ultimate beneficial owners if it is a company, politically exposed status.
Buyer03
To be evidenced
Source of funds
Loan, own funds, gift, sale of another property: every source is named and documented, and inconsistencies surface before the signature.
Financing04
Transmitted
Handover to the notary
The diligence file leaves complete. The notary redoes their own checks, the agency keeps the proof of its own.
FileTransactions and management
Two jobs under one licence,
two different diligences.
Acting as a transaction intermediary and managing property for owners are not the same business relationship. AML Company keeps the two apart rather than blending them.
Transaction intermediary
The business relationship is short and intense: it starts at the mandate and closes at the deed. Everything must be documented inside that window.
- Seller identified at the mandate
- Buyer identified at the offer
- Source of funds before the preliminary contract
Property manager
The management mandate lasts for years and your principals' rents pass through your accounts. Diligence there is ongoing rather than one-off.
- Instructing owner identified before the management mandate
- Rents and fund movements tracked
- Periodic review rather than a single check
Proportionate diligence
Not every sale
looks alike.
The risk lies in the structure, not in the price of the property. AML Company assesses every transaction on its parties, its financing and its geography.
Ordinary sale
Low- Two resident individuals
- Belgian mortgage loan
- Price in line with the market
Diligence
Simplified diligence
Sale to watch
Medium- Buyer is a legal entity
- Cash purchase with no loan
- Funds coming from outside
Diligence
Standard diligence
Sensitive sale
High- Foreign or politically exposed party (PEP)
- Price far off the property's value
- Interposed structure or quick resale
Diligence
Enhanced due diligence (EDD)
Platform
Compliance,
at the agency's pace.
Every duty of a real estate agent has its module, built for a portfolio of mandates rather than for a compliance department.
One file per transaction
Seller, buyer, property and financing live in the same file, from mandate to deed, with the history of every decision.
Mandate → deedTwo partiesTimestamping
Buyer as a legal entity
When a company buys, its CBE record (legal form, registered office, directors, activity) feeds the file and the ownership chain unfolds.
CBEUBO register
Source of funds
Every source of financing is named, evidenced and reconciled with the price. An unexplained gap becomes a control point, not an oversight.
Loan · own fundsSupporting documents
Sanctions and PEPs
Both parties are screened against the sanctions lists and politically exposed statuses, before the deed and not after.
SanctionsPEP
Managed portfolio
The properties under management get a scheduled periodic review, with an automatic reminder when a file ages.
Periodic reviewRemindersMulti-property
Ready for the inspection
Every file exports with its audit trail, in the order an inspection asks for it.
PDF exportAudit trailArchive
You see the buyer before anyone else. That is where diligence counts.
By the time the file reaches the notary, the essentials are already decided. AML Company documents what the agency actually checked, at the moment it checked it.
What the law expects
Your duties,
kept up to date for you.
A real estate agent applies the full diligence baseline, in transactions and in property management on behalf of third parties. AML Company turns it into guided steps, from the mandate to retention.
Legal basis: art. 5, §1, 30° of the Act of 18 September 2017
General information based on the Belgian framework; it is not legal advice.
- Identification and verification of the client's identity (KYC)
- Identification of the ultimate beneficial owners (UBO register)
- Assessment of money-laundering and terrorist-financing risks
- Ongoing diligence and monitoring of transactions
- Reporting suspicions to the CTIF
- Retention of the documents and appointment of an AMLCO
Frequently asked questions
Real estate
and anti-money laundering.
Are real estate agents obliged entities?
Yes. Art. 5, §1, 30° of the Act of 18 September 2017 covers the intermediary (sale, purchase, exchange, letting or transfer, whatever the rent) and the property manager who manages property on behalf of third parties. Co-ownership management (syndic) is not covered.
When must the client be identified?
As soon as the business relationship starts: at the signature of the mandate for the seller, and as soon as the offer is accepted for the buyer. Waiting for the preliminary contract means identifying too late.
Doesn't the notary already run those checks?
The notary is an obliged entity in their own right, which does not relieve the agency of its own duties. The two diligences coexist and each must be provable separately.
Must the buyer's source of funds be checked?
As soon as the risk level justifies it, and systematically under enhanced due diligence. The platform records the declared sources of financing and retains the supporting documents received.
Get started
Bring your agency into compliance.
Keep the proof.
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