Anti-money laundering insights: Real estate’s gaps and FIC’s global AML strategy

South Africa may soon exit the Financial Action Task Force’s (FATF) greylist. A Plenary decision is expected this month, following the country’s positive resolution of 22 action items, the National Treasury confirmed in a media statement on 31 July 2025.  

The role of estate agents

Estate agents could contribute to this happening sooner rather than later.

Classed as high-risk Designated Non-Financial Businesses and Professions (DNFBPs), they face heightened AML scrutiny from the FIC and PPRA to ensure compliance with global standards.

Yet, the Financial Intelligence Centre’s (FIC) 2024/25 report shows estate agents lagging in anti-money laundering (AML) compliance, with 30% missing Risk and Compliance Return (RCR) deadlines by March 2025, making a greylist exit less likely.  

(This Moonstone article summarises FIC’s 2024/25 annual report, which includes the body’s risk-based approach, aligned with 2025 global AML trends, to strengthening South Africa’s financial integrity.)

How hard will it be for real estate to comply?

Estate agents navigate dual regulation: FIC mandates for AML and combating terrorism financing, plus Property Practitioners Regulatory Authority (PPRA) rules for ethical conduct and fidelity fund compliance.  

Property’s allure for money launderers (including cash transactions above R50,000, trusts, or undervalued sales) makes it easy to see why, with illicit flows costing South Africa US$10 billion yearly, according to FIC. And the industry is not where it needs to be to manage those risks yet.

FIC inspections have flagged gaps in current industry practices, including patchy implementation of business risk assessments, Risk Management and Compliance Programmes (RMCPs), beneficial ownership checks, and targeted financial sanctions (TFS) screening.

The consequences of non-compliance can be severe. Section 45C(3)(d) of the amended FIC Act (FICA) empowers the FIC or supervisory bodies to impose administrative sanctions. The maximum financial penalty for legal persons (e.g. estate agencies) is R50 million, and for natural persons it is R10 million.

As the FICA supervisory body for property practitioners, the PPRA incorporates FIC inspections into its audits. Failure to comply can result in deregistration or suspension.  

But it is not only the risk of fines estate agents need to think about. Investec's analysis on greylisting impacts highlights SA's ongoing deficiencies in real estate supervision, exacerbating blocks on "global deals" like foreign buyer transactions. For estate agents, this means heightened KYC hurdles for international clients, potentially costing agencies international business opportunities.  

Impact spotlight

The FIC has made impressive progress. In 2024-25, the agency made R144 million in crime recoveries (up 46% year on year), and blocked R157.5m via 164 directives, driven by 3 104 reactive and 1 092 proactive reports. Hubs like the Asset Recovery Hub (R33m) and Reformed Fusion Centre (R93m in one case) show 13.4 million regulatory submissions fuelling action.  

Action for estate agents  

The Financial Action Task Force (FATF) launched a National Risk Assessment Toolkit to operationalise risk-based AML strategies, and spotlights real estate’s global vulnerabilities and key money laundering threats like shell company obfuscation and crypto-funded purchases.  

It urges enhanced due diligence, beneficial ownership transparency, and sectoral assessments for estate agents and other high-risk industries. Its interactive annexes provide templates to map corruption-linked laundering and emerging risks, directly supporting FIC’s goAML and RMCP requirements in SA’s greylisting context.  

Estate agents can leverage the National Risk Assessment Toolkit to refine RMCPs, prioritise TFS checks, and streamline RCRs in line with the regulators’ expectations. Viewing regulation as an enabler that helps streamline low-risk deals while fortifying high-risk ones, positions the sector for a positive post-greylist future. The FIC’s globally aligned strategy is a blueprint worth supporting.