AML in Real Estate: Source of Funds, Identity, and Global Risk Controls

by Sep 16, 2025

Real estate professionals face rising AML scrutiny across markets. This article breaks down identity verification, source of funds, and beneficial ownership rules in the U.S., Canada, UK, EU, and Australia – and shows how iComply helps automate compliance across agents, lawyers, and lenders.

Real estate is a prime target for financial crime. High-value transactions, opaque ownership structures, and limited oversight have made the sector vulnerable to money laundering worldwide.

From regulators to investigative journalists, scrutiny is intensifying, compliance expectations are evolving. Brokers, lawyers, developers, mortgage professionals, and title companies all have a role to play.

Shifting AML Expectations in Real Estate

United States

  • Regulators: FinCEN, state real estate commissions
  • Requirements: Geographic targeting orders (GTOs), beneficial ownership reporting (CTA), SARs, and KYC for buyers and entities

Canada

  • Regulators: FINTRAC, provincial real estate councils
  • Requirements: KYC, source of funds verification, PEP/sanctions screening, STRs, and compliance program requirements (as reinforced by the Cullen Commission)

United Kingdom

  • Regulators: HMRC, FCA (for lenders), SRA (for law firms)
  • Requirements: Client due diligence, UBO checks, transaction monitoring, and compliance under MLR 2017

European Union

  • Regulators: National AML authorities under AMLD6
  • Requirements: Risk-based customer due diligence, UBO transparency, STRs, and GDPR-aligned reporting

Australia

  • Regulator: AUSTRAC (legislation pending for real estate-specific coverage)
  • Requirements: AML risk management for law firms, lenders, and trust accounts; expected expansion to include property professionals

Real Estate-Specific Risk Factors

1. Complex Ownership Structures
Use of shell companies, nominees, and trusts can obscure true buyers.

2. Source of Funds Obscurity
Large cash deposits or offshore funding require enhanced scrutiny.

3. Multi-Party Transactions
Buyers, sellers, agents, lawyers, lenders, and developers often use disconnected systems.

4. Regulatory Patchwork
Requirements vary by jurisdiction and professional role.

How iComply Helps Real Estate Professionals Stay Compliant

iComply enables unified compliance across real estate workflows—from individual onboarding to multi-party coordination.

1. Identity and Entity Verification

  • KYC/KYB onboarding via secure, white-labeled portals
  • Support for 14,000+ ID types in 195 countries
  • UBO discovery and documentation

2. Source of Funds Checks

  • Collect and validate financial statements, employment records, or declarations
  • Risk-based automation of EDD triggers
  • Document retention for regulator inspection

3. Sanctions and Risk Screening

  • Real-time screening of all participants (buyers, sellers, brokers, law firms)
  • Automated refresh cycles and trigger alerts

4. Cross-Party Case Collaboration

  • Connect agents, legal counsel, and lenders in a single audit-ready file
  • Assign roles, track tasks, and escalate within shared dashboards

5. Data Residency and Privacy Compliance

  • Edge computing ensures PII is encrypted before upload
  • Compliant with PIPEDA, GDPR, and U.S. state laws
  • On-premise or cloud deployment options

Case Insight: Vancouver Brokerage

A Canadian real estate firm used iComply to digitize ID checks and SoF verification for domestic and foreign buyers:

  • Reduced onboarding time by 65%
  • Flagged two nominee structures linked to offshore trusts
  • Passed a FINTRAC audit with zero deficiencies

Final Take

Real estate professionals can no longer afford fragmented compliance. With global pressure mounting, smart automation ensures faster onboarding, better oversight, and fewer audit risks.

Talk to iComply to learn how we help brokers, lawyers, and lenders unify AML workflows – without slowing down the deal.

Vaidyanathan Chandrashekhar

Vaidyanathan Chandrashekhar

Advisors

“Chandy,” is a technology and risk expert with executive experience at Boston Consulting Group, Citi, and PwC. With over two decades in financial services, digital transformation, and enterprise risk, he advises iComply on scalable compliance infrastructure for global markets.
Thomas Linder

Thomas Linder

Advisors

Thomas is a global tax and compliance expert with deep specialization in digital assets, blockchain, and tokenization. As a partner at MME Legal | Tax | Compliance, he advises iComply on regulatory strategy, cross-border compliance, and digital finance innovation.
Thomas Hardjono

Thomas Hardjono

Advisors

Thomas is a renowned identity and cybersecurity expert, serving as CTO of Connection Science at MIT. With deep expertise in decentralized identity, zero trust, and secure data exchange, he advises iComply on cutting-edge technology and privacy-first compliance architecture.
Rodney Dobson

Rodney Dobson

Advisors

Rodney is the former President of ADP Canada and international executive with over two decades of leadership in global HR and enterprise technology. He advises iComply with deep expertise in international service delivery, M&A, and scaling high-growth operations across regulated markets.
Praveen Mandal

Praveen Mandal

Advisors

Praveen is a serial entrepreneur and technology innovator, known for leadership roles at Lucent Bell Labs, ChargePoint, and the Stanford Linear Accelerator. He advises iComply on advanced computing, scalable infrastructure, and the intersection of AI, energy, and compliance tech.
Paul Childerhose

Paul Childerhose

Advisors

Paul is a Canadian RegTech leader and founder of Maple Peak Group, with extensive experience in financial services compliance, AML, and digital transformation. He advises iComply on regulatory alignment, operational strategy, and scaling compliance programs in complex markets.
John Engle

John Engle

Advisors

John is a seasoned business executive with senior leadership experience at CIBC, UBS, and Accenture. With deep expertise in investment banking, private equity, and digital transformation, he advises iComply on strategic growth, partnerships, and global market expansion.
Jeff Bandman

Jeff Bandman

Advisors

Jeff is a former CFTC official and globally recognized expert in financial regulation, fintech, and digital assets. As founder of Bandman Advisors, he brings deep insight into regulatory policy, market infrastructure, and innovation to guide iComply’s global compliance strategy.
Greg Pearlman

Greg Pearlman

Advisors

Greg is a seasoned investment banker with over 35 years of experience, including leadership roles at BMO Capital Markets, Morgan Stanley, and Citigroup. Greg brings deep expertise in financial strategy and growth to support iComply's expansion in the RegTech sector.
Deven Sharma

Deven Sharma

Advisors

Deven is the former President of S&P and a globally respected authority in risk, data, and capital markets. With decades of leadership across financial services and tech, he advises iComply on strategic growth, governance, and the future of trusted data in AML compliance.