Real Estate Professional

Real estate professionals may be knowingly or unknowingly involved in all-cash real estate transactions by:

• Accepting or facilitating large sums of cash without verifying the source of funds, thereby bypassing mortgage-related due diligence.
• Overlooking suspicious patterns of structured cash payments, which enables illicit funds to be placed into property assets.
• Providing minimal documentation requirements, allowing adversaries to obscure their financial background and purchase history.

Real estate professionals are enlisted to:

• Facilitate property sales at artificially high or low prices, allowing criminals to absorb or conceal illicit funds.
• Conduct repeated transactions with inconsistent valuations, obscuring the genuine scale of criminal proceeds and creating challenges for banks verifying legitimate property values.

Real estate professionals handling auction sales are exploited by criminals who:

• Employ nominees or shell companies to place bids, masking the true source of funds.
• Flip properties at manipulated prices (below or above market) for repeated layering.

This complicates financial institutions’ due diligence processes and obstructs efforts to link illicit funding to the ultimate beneficiaries.

Real estate professionals may be exploited or complicit when:

• Facilitating acquisitions or leases that obscure beneficial ownership through complex corporate structures.
• Overlooking suspicious spikes in rental or operational income, enabling illicit funds to blend with legitimate revenues.

Real estate brokers or agents may be knowingly or unknowingly involved in:

• Facilitating property purchases without conducting thorough due diligence on the customer’s source of funds.
• Handling large transactions that integrate illicit proceeds into seemingly legitimate property deals, reducing financial institutions’ visibility of suspicious activity.
• Overlooking beneficial ownership details, allowing criminals to layer and conceal the true owners of foreign real estate assets.

They facilitate property transactions that meet CBI/RBI requirements by:

• Handling sales that may involve artificially inflated property values.
• Coordinating closings or paperwork that can disguise true investment amounts, potentially overlooking red flags related to the origins of funds.

Real estate professionals support farmland or commercial property acquisitions linked to illicit proceeds by:

• Participating in valuations that may be overstated or understated to camouflage actual funding sources.
• Handling documentation and negotiations that obscure the true beneficiary or purpose of the purchase.
• Further legitimizing property ownership, complicating financial institutions’ identification of suspicious capital flows.

Real estate professionals can be used, knowingly or unknowingly, to:

• Structure property sales or acquisitions via shell companies or nominee buyers, concealing true ownership.
• Accept large cash deposits and facilitate transactions that bypass standard KYC checks.

These practices obscure illicit funds and pose significant challenges to financial institutions' AML efforts.

Real estate professionals manage or oversee property auctions, creating vulnerabilities when:

• Lax or non-existent KYC and beneficial ownership checks allow straw buyers or shell entities to participate undetected.
• Distressed auction conditions are exploited to underbid or overbid without proper scrutiny.
• Rapid flips of auctioned properties are not flagged, complicating financial institutions’ efforts to identify suspicious transaction patterns.

Real estate professionals facilitate property purchases and sales, sometimes unwittingly enabling rapid flips for illicit operators. By coordinating listings, showings, and closings:

• They streamline transactions that can obscure the true source of funds.
• Their routine involvement in real estate procedures lowers suspicion, allowing criminals to complete quick resales through ostensibly normal channels.

Real estate professionals facilitate property transactions by:

• Identifying and negotiating deals on behalf of buyers or sellers.
• Overseeing property searches, inspections, and closings, sometimes with limited verification of ownership or funding sources.
• Potentially overlooking suspicious price fluctuations or opaque beneficial ownership structures.

This can undermine financial institutions’ due diligence, as mortgage services or payment processing may fail to detect hidden illicit funds introduced through real estate transactions.

Real estate professionals, including complicit property managers, enable rental income schemes by:

• Overlooking or facilitating falsified tenancy agreements and inflated rent payments.
• Managing tenant records that merge legitimate and illicit rent inflows, obscuring the funds’ true origin from financial institutions.

Real estate professionals manage transactions that can be used to purchase properties under complex corporate structures. Such arrangements help sanctioned actors hide their involvement in high-value acquisitions, complicating financial institutions' efforts to identify and screen ultimate beneficiaries.