Legal Q&A · Property Transfer

Does a real estate agency have anti-money laundering (AML) obligations?

Law as at 21 July 2026

Answered by , Czech and Slovak attorney, admitted to the Slovak and Czech Bars (SAK 300422 · ČAK 19654).

Short answer

Yes. A real estate agency is an obliged entity under the Act on Protection against the Legalisation of Proceeds of Crime. It must identify and verify clients, perform risk-based due diligence, have an internal AML programme and report unusual business transactions to the Financial Intelligence Unit. Failure to comply can lead to substantial penalties.

Is a real estate agency an obliged entity?

Act No. 297/2008 Z. z. on Protection against the Legalisation of Proceeds of Crime (AML) expressly includes among obliged entities legal or natural persons authorised to broker the sale, letting and purchase of real estate (Section 5(1)(i)). For sales and purchases, this applies without a threshold; for lettings, only where the monthly rent is at least EUR 10,000. A real estate agency therefore has AML obligations in practically every property sale or purchase.

What obligations follow?

The status of an obliged entity entails, in particular:

  • identifying and verifying the client (and the ultimate beneficial owner) before the transaction;
  • customer due diligence proportionate to the risk (standard, simplified or enhanced);
  • an internal AML programme and a designated responsible person;
  • identifying and reporting unusual business transactions to the Financial Intelligence Unit;
  • retaining data and documents for the statutory period.

An unusual business transaction includes, for example, a transaction with no apparent economic purpose, one in which the client refuses identification, or one where the amount of funds is inconsistent with the client’s circumstances (Section 4).

Why it matters

Breaching AML obligations exposes an agency to administrative penalties and reputational risk. A functioning internal programme, trained agents and a clear procedure for suspicious transactions are essential. We prepare AML documentation and procedures through our legal services for real estate agencies, train agents through real estate agent training, and provide ongoing updates through our retainer for real estate agencies.

This answer provides general information on the law as at 21 July 2026. It does not constitute legal services or replace an assessment of an individual case. The details of your situation may differ. Book a consultation to discuss them.

More legal questions

All questions and answers
  1. How can I find out who previously owned a property? A standard title sheet extract shows only the current position. A copy of the original title sheet with a chronology of changes contains the registration history; the district office’s cadastral department issues it on request for an administrative fee. If you need to investigate further, the owner’s legal predecessors and successors also have access to the document collection — including a buyer after the transfer.
  2. Must I approach the other co-owners before selling my share in a property? Yes. When a co-ownership share is transferred, the other co-owners have a statutory pre-emption right. You must first offer them the share on the same terms as the intended sale to a third party. Transfers to a close person are exempt: a direct-line relative, sibling, spouse or another person meeting the statutory definition. An overlooked co-owner can challenge a transfer that bypasses this right.
  3. How does a reservation agreement work, and what happens to the reservation fee? A reservation agreement is an unnamed contract: the law does not regulate it specifically, but it is valid if it does not conflict with the law’s content or purpose. Its wording is decisive, particularly the parties’ commitments and what happens to the reservation fee if no purchase agreement is concluded. An agreement with a consumer must not contain unfair terms.
  4. Defects appeared after I bought the property. What can I claim from the seller? If a defect later emerges that the seller did not disclose, you are entitled to a reasonable reduction in the purchase price. If it makes the property unusable, or the seller gave false assurances about its qualities, you may withdraw from the agreement. Speed is crucial: notify the seller without undue delay, and no later than 24 months after taking possession, or your rights expire.

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Mgr. Patrik Tulinský, LL.M. Czech and Slovak attorney · SAK 300422 · ČAK 19654

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