Real Estate KYC: AML/CFT vigilance for high-value transactions

Since AMLD4 (transposed into French law in 2016), reaffirmed by AMLD6 (transposed June 2025), three real-estate professions are subject to the anti-fraud and anti-money-laundering rules, known as AML/CFT:

• Real-estate agents under the Hoguet Act: transactions and rental management
• Notaries: authentic acts of sale, gift, succession
• Chartered accountants who advise on real-estate operations, including SCI and SCPI structuring

The French Monetary and Financial Code, in its articles L561-2 and L561-4-1, sets your identification and vigilance obligations. The enhanced-vigilance threshold sits at €100,000 for ordinary operations, but that threshold falls away in the presence of risk indicators: cash transactions, buyers from high-risk third countries (FATF list), complex legal structures, multiple designations within an SCI.

We calibrate the framework on three levels of vigilance, proportionate to risk:

• Standard vigilance: you apply the baseline check to ordinary transactions below €100,000
• Enhanced vigilance: you trigger deeper checks above €100,000, or in the presence of risk indicators
• Complementary vigilance: we identify politically exposed persons (PEPs) and beneficial owners — qualifying the BOSS (beneficial owner) is a hard point on SCIs, SCPIs and OPCIs

Fast, reliable identification of your buyers is a major friction point in real-estate transactions. Whether you sign a lease, a preliminary sales agreement or structure an SCI, our electronic identity verification (eIDV) through data validates the majority of your clients without requesting an extra document. For foreign buyers, you access coverage across 197 countries: useful from day one, including in jurisdictions where local sources are fragmented.

Proving the source of funds is the central pillar of real-estate vigilance. We complement the declarative documents with a data-driven analysis of the buyer's financial profile: income stability, address tenure, presence on tax bases, consistency with the transaction amount. Transactional data reveals what a document alone cannot prove. Because today, everything can be forged… but a real life of verified purchases cannot be invented.

PEP (politically exposed persons) screening is mandatory and continuous. We query in real time European and international PEP databases, as well as EU, UN and OFAC sanctions lists. A PEP qualification automatically triggers the enhanced vigilance required by the French Monetary Code.

For buyers from or residing in a high-risk third country (FATF list), enhanced vigilance is systematic. You access official registries, sanctions and PEP lists across more than 197 countries — useful for international buyers of prestige or commercial real estate, and for SCIs or SCPIs with foreign associates.

Our structural conviction fits in one sentence: "Because today, everything can be forged — except real life and what people actually buy." An ID can be forged, a selfie deepfaked, a bank statement fabricated. But an individual who pays their energy, rent or mortgage at the same address for three years cannot be invented. This data is precious to verify a source of funds in real estate.

Four canonical families of sources feed the verification:

Our approach is a necessary complement to the other KYC phases (Know Your Customer, customer identity verification) — biometrics, document checks — and has become essential to secure onboarding and to fight fraud on high-value transactions. You keep your existing checks; we add the transactional layer that anchors them in real life. The technology integrates natively into your business software — notarial solutions (Hoxia, AC3, La Solution Crypto), generalist agency software, SCPI/OPCI ERPs.

Failing your real-estate AML/CFT obligations exposes you to a range of heavy sanctions. The French National Sanctions Commission (CNS) and the DGCCRF are competent for Hoguet-Act real-estate agents. The Higher Council of the French Notariat and the ACPR oversee notaries and chartered accountants.

Three steps structure an effective real-estate KYC upgrade:

1. Audit of the existing setup: together we map your friction points, measure the compliance of your current processes and identify the gap with AMLD6 and Tracfin requirements. We can also run a free audit of your existing data, to measure your current data assets and the optimum reachable against your goals.

2. eIDV integration via API: we plug the solution into your business software, deploy automated PEP and sanctions screening, configure tiered vigilance and identify the beneficial owner (BOSS) on your legal structures (SCI, SCPI, OPCI).

3. Tracfin reporting procedure: you pilot an integrated suspicion-report workflow, documented traceability and alert handling.

We support this journey end-to-end. Complementarity with your existing stack is guaranteed.

"Our job isn't to sell data at any cost. It's to find, for you, the data that resolves your specific case."