Real Estate Broker

Recognizing unusual transactions

As a broker, you are familiar with the practices within your line of business. Whether a transaction is considered unusual depends largely on your professional judgment. Your judgment is consistent with what is considered unusual within your profession. In addition to your judgment, there are situations that are unusual by nature and should therefore be reported.

If a situation arises as described in the examples below (not exhaustive), this is a reason to further examine whether the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses. It is not necessary to determine with certainty that the above-mentioned crimes have been committed. You merely need to have an assumption that the transaction can be related to one of these crimes.
If you believe that the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses, you are required to report this under the subjective indicator.

Red flags – Real estate

• The buyer of registered property allows a lower selling price than the market value to be included in the deed. The buyer pays the seller the difference in price directly
• Real estate is bought or sold in the name of others
• Performing various transactions to conceal the origin of the funds
• Choosing to invest in apartments or similar buildings, without being aware or interested whether they are or will be occupied
• The purchase and sale of real estate within a considerably short period of time, where the client is not making a profit or has no interest in making a profit
• Prior to the purchase the client shows no interest in inspecting the property at the location of the property or the calculated costs for repairing the property
• The client has objections or is reluctant to meet the broker or the notary in person

Typologies: