Real estate agent

Recognizing unusual transactions

As a service provider (Real estate agent), you are aware of the practices in your industry. Determining whether a transaction is classified as unusual depends, to a great extent, on your professional opinion. Your opinion corresponds with what is considered unusual within your profession. In addition to your opinion, there are circumstances of an unusual nature which must therefore be reported.


If one of the scenarios described in the general examples below (which are not exhaustive) arises, then this is cause to further examine whether the transaction could be connected with money laundering and/or terrorist financing. If you suspect activities of money laundering or terrorist financing, then you must report it.

Red flags – Real estate agent

  • The buyer of real estate has a selling price recorded in the deed which is lower than the market value. The buyer privately pays the seller the difference in price
  • The purchase or sale of real estate takes place in the name of other parties
  • Carrying out a variety of transactions in order to conceal the origin of the funds
  • Choosing to invest in apartments or similar buildings without being aware of or interested in these being occupied
  • Buying and selling real estate in a considerably short period of time, without the client making a profit or taking an interest in making a profit
  • Prior to the purchase the client does not take any interest in inspecting the real estate in the location of the real estate or in inspecting the expenses that will be incurred to repair the real estate
  • The client objects to or is reticent with regard to meeting the real estate agent or civil-law notary in person