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. We want to withdraw from the purchase of a house because of a serious defect. How is the money returned and what happens in the cadastre? You may withdraw for a defect if the defect renders the house unusable, or if the seller’s assurance about its qualities has proved untrue. A valid withdrawal cancels the agreement from the outset, the seller returns the purchase price and you return the house. The cadastre records the seller as owner again by a declaratory record, provided the withdrawal is not disputed; if the seller challenges it, ownership will be decided by a court.
  2. What information must an estate agency give a client before an agency agreement is signed? Where the client is a consumer, the estate agency must state clearly before signing what service it provides, who it is, how much the commission will be or how it is calculated, for how long the agreement is concluded and how it can be brought to an end. Where the agreement is signed at a viewing, at the client’s home or at a distance, further information is required, including instructions on withdrawal and a model form, and all the information given becomes part of the agreement. In every case, it is the agency that must prove the client received it.
  3. Our agents work as self-employed contractors. Does the estate agency risk a penalty for illegal employment? Cooperation between an estate agency and agents who are self-employed is lawful if the agent works independently. What matters is how the relationship actually operates: if the agent works in a subordinate position, personally, on the agency’s instructions and in its name, the work is dependent work, and dependent work cannot be performed under a commercial contract. The agency then risks a fine for illegal employment from EUR 4,000, or at least EUR 8,000 where two or more people are concerned at the same time, up to EUR 200,000.
  4. We hold a cooperative apartment as a married couple. Can one of us transfer it without the other? If the right to a tenancy of a cooperative apartment arose during the marriage, the spouses are joint members of the cooperative and both must sign the membership rights transfer agreement. If one spouse held membership before the wedding, that spouse is the sole member, but the apartment is in their joint tenancy and the transfer directly affects the other spouse. It is therefore safe to have both spouses’ signatures on the agreement, including when buying from a married couple.

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

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