AML/CFT: Supporting real estate professionals in meeting their obligations
Since 2024, a LuxReal expert committee has been exploring the challenges of anti-money laundering and countering the financing of terrorism (AML/CFT) faced by the real estate professionals. To mark the publication of its first technical note, Emmanuelle Ramponi (Bright4Funds Partners), Vice-President of LuxReal’s Advisory Board, discusses why the group was formed and what it aims to achieve.
Why are AML/CFT issues important for real estate professionals?
This is an issue that concerns everyone in the real estate ecosystem in Luxembourg. Currently, the sector carries a high inherent risk of money laundering and a medium inherent risk of terrorist financing. Real estate transactions can be used to conceal the illicit origin of funds and integrate them into the economy giving them an appearance of legitimacy. The professionals involved in the sector, from estate agents and real estate developers to lawyers, fund managers or banks, must therefore fulfil the AML/CFT obligations applicable to their respective activities.
Emmanuelle Ramponi
Vice-President of LuxReal’s Advisory Board
What led to the creation of a working group on these issues within LuxReal?
We were working on these issues for many years to support our members before the creation of our dedicated committee. In 2024, we have decided to create a formal group of AML/CFT experts to take this work further, all of them coming from our supporting members and representing different real estate professions. The group is co-chaired by Sandrine Périot (Arendt Regulatory & Consulting) and Caroline Dufresne (BNPP REIM).
The aim of our committee is to facilitate discussions around AML/CFT laws & regulations as well as professionals’ responsibilities, while giving the sector a stronger voice in consultations conducted by regulatory authorities such as AMLA or the CSSF. We also liaise with our peers, being other Luxembourg professional organisations, to exchange our perspectives.
How can you support AML/CFT compliance across a diverse real estate sector?
All professionals in the real estate sector have a role to play in preventing money laundering and terrorist financing, regardless of their role or the size of their organisation. However, not everyone has the same resources: an independent estate agent cannot rely on the same teams as an international law firm or an Investment Fund Manager to carry out the necessary measures. We want to support our members by sharing knowledge and practical guidance to help them fulfil their responsibilities more effectively.
You are publishing your first technical note this autumn. What does it offer?
The expert committee’s work has evolved over time. Our group seeks to provide practical support to Luxembourg real estate professionals in meeting their AML/CFT obligations. That first technical note serves that purpose.
We plan to launch a series of technical notes around the key AML/CFT challenges faced by the real estate sector. That first 8-page paper “AML/CFT Risk Factors Guidance for the Luxembourg Real Estate Sector” offers a comprehensive overview over these risks and illustrates them with practical examples.
Last but not least, I would like to express my special thanks to the expert committee, and in particular to Caroline Dufresne (BNPP REIM), Lars Weineck (Dentons) and Déborah Cugnot (Forvis Mazars) for having actively contributed to that first issue.
Please click on the below link to read the technical note.