International Real Estate

Criminals purchase or invest in foreign properties—often through offshore accounts or shell entities—to hide ownership and shift illicit funds across borders. By exploiting countries with lax real estate oversight or minimal beneficial-ownership disclosure, they further complicate investigative efforts and obscure the money trail. They commonly employ multi-layered ownership structures, sometimes routed through shell companies or trusts, to disguise the ultimate beneficial owners and conceal the origin of illicit proceeds. In jurisdictions lacking centralized registries or robust transparency requirements, law enforcement struggles to trace real estate transactions back to the true owners, allowing criminals to integrate laundered funds into seemingly legitimate property portfolios. Opportunistically, corrupt actors and fraudsters may combine several cross-border transactions, placing additional barriers to timely verification of beneficial ownership and challenging regulatory monitoring of suspicious foreign property acquisitions.

[
Code
T0010.003
]
[
Name
International Real Estate
]
[
Version
1.0
]
[]
[]
[
Risk
Product Risk, Jurisdictional Risk
]
[
Created
2025-03-12
]
[
Modified
2025-04-02
]

Real Estate Purchases Abroad

Tactics

ML.TA0009
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By investing illicit capital in foreign real estate, criminals embed laundered funds under the guise of legitimate property acquisitions, effectively merging them into the legal economy.

Risks

RS0002
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Product Risk
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Overseas real estate as a financial product often has fewer AML checks or disclosure requirements, allowing criminals to convert illicit funds into tangible assets under minimal scrutiny. By leveraging inherent gaps in real estate due diligence and oversight, they effectively obscure the illicit origin of proceeds.

RS0004
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Jurisdictional Risk
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This technique primarily exploits cross-border real estate purchases in secrecy-friendly jurisdictions with lax AML regulations and minimal beneficial ownership disclosure. This makes it exceedingly difficult for authorities to trace illicit funds and identify the true owners behind these property transactions.

Indicators

IND01493
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Large international wire transfers from multiple offshore entities into an account used exclusively for purchasing foreign real estate.

IND01494
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Property transactions in high-value ranges that exceed the customer’s stated income or business revenues without documented justification.

IND01495
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Customer persistently delays or refuses to provide details on beneficial ownership for offshore entities used in foreign property purchases.

IND01496
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Frequent real estate acquisitions in jurisdictions characterized by minimal disclosure requirements and lax regulatory oversight.

IND01498
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Multiple foreign real estate holdings formally registered under different shell companies but administered by the same individuals or signatories.

IND01499
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Overlapping control persons or contact information across multiple offshore corporations collectively used in cross-border property investments.

IND01500
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Frequent property flips with large valuation discrepancies completed within short time frames, lacking legitimate business justification.

Data Sources

  • Consolidates risk assessments and regulatory information on specific countries or regions.
  • Identifies jurisdictions known for weak transparency or lax oversight in property transactions.
  • Assists analysts in monitoring high-risk geographic targets for potentially illicit real estate investments.
  • Includes official filings such as tax returns, balance sheets, and profit-and-loss statements.
  • Enables comparison of declared income or business revenues against high-value foreign real estate purchases.
  • Supports analysis of financial inconsistencies or anomalies indicative of money laundering activity through offshore property ownership.

Contains in-depth records of trusts, including settlors, trustees, beneficiaries, and related financial accounts.

  • Clarifies ownership structures where trusts are used to hide real estate holdings in foreign jurisdictions.
  • Aids in identifying ultimate beneficial owners and detecting potentially suspicious trust arrangements supporting cross-border property transactions.
  • Aggregates identity details, public filings, and entity information from government registries and open sources.
  • Aids in correlating personal identifiers, signatories, or contact information across multiple offshore corporations and real estate holdings.
  • Enhances detection of overlapping control persons in multi-entity structures used to obscure foreign property ownership.
  • Contains verified customer identification details, beneficial ownership information, historical account relationships, and risk profiles.
  • Facilitates comparison between declared customer financial circumstances and extensive foreign property transactions.
  • Supports enhanced due diligence to uncover suspicious or unverified ownership structures in cross-border real estate deals.
  • Provides detailed information on property purchases and transfers, including addresses, transaction dates, purchase values, and involved parties.
  • Allows identification of foreign real estate acquisitions and tracking of property flipping or rapid sales.
  • Facilitates verification of beneficial ownership data for overseas properties linked to shell companies or trusts, helping uncover hidden ownership structures in cross-border laundering schemes.
  • Captures transaction details for cross-border payments, including amounts, originating and beneficiary banks, jurisdictions, and settlement routes.
  • Enables monitoring of funds transferred from offshore sources into foreign real estate acquisitions.
  • Helps detect unusual cross-border flows potentially linked to laundering via foreign property holdings.
  • Contains official registration data, shareholders, directors, and incorporation details of firms, including offshore entities.
  • Enables tracing of multi-layered corporate structures and identifying true beneficial owners behind shell companies holding foreign real estate.
  • Supports detection of suspicious or undisclosed cross-border ownership arrangements linked to illicit property investments.

Mitigations

Identify jurisdictions known for weak real estate oversight, corruption, or minimal beneficial owner disclosure, and assign them a high-risk rating. Impose additional due diligence, stricter transaction limits, or specialized approvals for real estate purchases linked to these regions to reduce exposure to illicit cross-border property deals.

For high-risk international property transactions, require exhaustive documentation of beneficial ownership, source of funds, and detailed property records. Use local expertise or reputable third-party validation to confirm property authenticity and valuation. Where multiple ownership layers exist, verify each intermediary entity's registration and control structures to detect undisclosed owners or nominees.

Collect and verify identity and beneficial ownership details from clients engaged in foreign property investments, ensuring they align with official land records and corporate filings. If discrepancies or undisclosed controlling parties arise, escalate to enhanced due diligence procedures or deny the transaction.

Implement specialized monitoring scenarios for transactions involving foreign property purchases, particularly from secrecy-friendly jurisdictions or shell entities. Flag large or recurring cross-border wires used for real estate acquisitions that deviate from the customer’s known profile. Investigate short-term property flips, inflated valuations, or repeated high-value purchases that indicate layering or integration of illicit funds.

Screen beneficial owners, counterparties, and associated entities involved in foreign real estate transactions against sanctions lists, PEP databases, and adverse media before processing. Confirm that no restricted parties are exploiting cross-border real estate deals to disguise illicit capital or evade sanctions controls. Escalate flagged matches promptly for further investigation or action.

Leverage public property records, real estate databases, and relevant media—including foreign language sources—to verify the existence, ownership, and value of overseas properties. Cross-check corporate registries to detect overlapping control persons across multiple shell companies used for real estate acquisitions. These checks expose inconsistencies and concealed beneficial owners in cross-border property deals.

Restrict or deny financial services for foreign real estate purchases when a client fails to document legitimate beneficial ownership or if the jurisdiction is known for minimal regulatory controls. This directly prevents criminals from converting illicit funds into offshore properties that obscure the true origin of the money.

Instruments

  • Criminals route illicit proceeds through offshore or multiple bank accounts to fund foreign property acquisitions.
  • Minimal transparency requirements in certain jurisdictions allow layering and integration by distancing funds from their illicit origins.
  • These accounts provide the liquidity needed for cross-border transactions while shielding beneficial owners behind complex transfer chains.
IN0013
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  • Criminals directly purchase foreign properties to integrate illicit funds, exploiting jurisdictions with lax or minimal beneficial ownership disclosure.
  • By registering these assets through multi-layered corporate or trust structures, they obscure the real source of the funds and the identity of the actual owners.
  • The properties appear as legitimate acquisitions, complicating tracing efforts by investigators.
  • Criminals place foreign properties into trust arrangements, obscuring who truly benefits from the real estate.
  • The split between legal and beneficial ownership in trust structures makes it difficult for authorities to trace funds back to the actual owners.
  • Multi-layered trust setups further mask the involvement of illicit proceeds in overseas property transactions.
  • Criminals create or use companies that issue bearer shares to acquire or hold foreign real estate.
  • Ownership is transferred through the physical possession of the share certificates, preventing the registration of beneficial owners.
  • This high level of anonymity enables illicit proceeds to be funneled into real estate investments without revealing who actually controls the company.
  • Criminals establish or acquire ownership stakes in shell companies that purchase foreign real estate.
  • Holding property through these entities detaches legal title from the ultimate individual, concealing the real owner’s identity.
  • The layering of corporate structures hinders law enforcement’s ability to connect the illicit funds to the true beneficiaries.

Service & Products

  • Facilitate foreign property purchases that integrate illicit funds under the guise of legitimate transactions.
  • Limited cross-border due diligence can enable criminals to conceal beneficial ownership and the illicit source of funds.
  • Enable cross-border fund transfers with limited oversight, financing foreign property purchases through opaque offshore accounts.
  • Banking secrecy laws in certain jurisdictions impede efforts to trace illicit funds used for real estate acquisitions.
  • Real estate brokers or agents may unwittingly process transactions funded by illicit wealth if identification checks are weak.
  • Criminals exploit minimal transparency around beneficial ownership to shield themselves behind layered property purchases.
  • Allow criminals to commit funds to foreign real estate portfolios, blending illicit capital with legitimate investments.
  • Multi-layered investment vehicles hinder investigators’ ability to identify true owners or trace illegal proceeds.
  • Facilitate the creation of offshore shell companies with minimal reporting requirements to hold foreign properties.
  • Criminals leverage secrecy jurisdictions to shield the real source and beneficiaries of illicit funds.
  • Criminals set up trusts or corporate vehicles to obscure beneficial ownership of foreign properties.
  • Nominee directors and intricate layering hamper authorities’ attempts to link the real owner to the laundered assets.

Actors

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.

These service providers facilitate the formation and administration of trusts or corporate vehicles used for:

  • Establishing multi-layered structures that shield beneficial owners from scrutiny, enabling criminals to route funds through multiple jurisdictions.
  • Creating and maintaining corporate records, registered offices, and nominee arrangements that obscure links between property holdings and illicit fund sources.
  • Complicating financial institutions’ due diligence efforts by dispersing ownership across various trusts, companies, or offshore entities.

Criminals use international real estate to move or hide illicit funds by:

  • Investing in foreign properties under personal or proxy names to obscure the true source of funds.
  • Exploiting jurisdictions with lax real estate regulations, making it difficult for financial institutions to identify suspicious transactions.
  • Combining multiple cross-border transactions to further complicate ownership tracing and hinder law enforcement inquiries.

These entities, often established offshore, enable criminals to:

  • Hold real estate assets behind corporate veils, preventing financial institutions from linking properties to the ultimate beneficial owner.
  • Employ multi-layered ownership structures that obscure transactional records and shield illicit capital.
  • Evade stringent beneficial ownership disclosure requirements, allowing launderers to disguise large cross-border property investments.
AT0068
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Nominees are enlisted to:

  • Legally hold title or manage foreign properties on behalf of criminals, masking the true purchasers’ identities.
  • Sign documents and appear in official records instead of the beneficial owners, impeding financial institutions’ efforts to identify suspicious property acquisitions.
  • Incur the administrative obligations of ownership while shielding the real parties behind cross-border real estate deals.

References

  1. ESAAMLG (Eastern and Southern Africa Anti Money Laundering Group). (2013). Typologies report on money laundering through the real estate sector in the ESAAMLG region. ESAAMLG. https://www.esaamlg.org/reports/TYPOLOGIES-REPORT-ON-ML-THROUGH-THE-REAL-ESTATE-SECTOR..pdf

  2. Financial Action Task Force (FATF) & Organisation for Economic Co-operation and Development (OECD). (2022, July). Guidance for a risk-based approach Real Estate Sector. FATF/OECD. http://www.fatf-gafi.org/publications/documents/Guidance-RBA-Real-Estate-Sector.html