The AMLR from 10 July 2027: what changes for your firm

On 10 July 2027, Regulation (EU) 2024/1624, the EU's anti-money-laundering regulation (AMLR), starts to apply. It is a regulation, not a directive: it applies directly in every member state, in the same words, without waiting for national law.

For property firms, six points matter.

1. Who it covers. Estate agents and other real estate professionals acting as intermediaries in property transactions, including lettings with a monthly rent of €10,000 or more (Article 3(3)(d)). Notaries and lawyers are covered when they take part in property or company transactions (Article 3(3)(b)), and trust and company service providers are covered as well (Article 3(3)(c)).

2. Who your customer is. For estate agents, both parties to the transaction: the side that instructed you and the side that did not (Article 19(6)(c)).

3. What the check covers. Nine measures, from verifying identity and beneficial ownership to sanctions, politically exposed persons and authority to act (Article 20(1)). How far you go on each depends on the risk (Article 20(2)).

4. When. For estate agents, verification takes place once an offer is accepted by the seller or lessor, and in all cases before any funds or property are transferred (Article 23(1)).

5. Who owns the company. Beneficial owners are the people who hold an ownership interest or who control the company, directly or indirectly (Article 51). If no beneficial owner is found, record that, then identify and verify the senior managing officials (Article 22(2)).

6. How long you keep it. Five years from the end of the business relationship or the transaction, or from a refusal. After that, personal data is deleted (Article 77(3)).

What Koheriant Verify does

You send your client one link per deal. They fill in the company, the signatory and the owners, including how each owner holds control, and upload the company extract. Verify screens every entity and beneficial owner against a third-party sanctions and PEP source. Your compliance officer reviews the file and decides. The record is kept, dated and ready for the supervisor.

In English and Dutch, hosted in the EU.

See it work: koheriant.com

Important

Koheriant is not a law firm and does not give legal advice. This page summarises our reading of Regulation (EU) 2024/1624 for general information only.

Koheriant Verify is software that helps your firm collect, screen and keep client due diligence records. Koheriant does not review client files and does not make due diligence or risk decisions. Screening results come from a third-party source and may be incomplete or out of date. Your firm remains responsible for meeting its obligations under the Regulation and national law.

Please confirm with your own legal counsel that your use of Verify meets your firm's requirements.