Conveyancing red flags: practical indicators for property transactions

Property is one of the most attractive destinations for criminal money: large values move in single transactions, ownership confers respectability, and the professionals involved lend the deal legitimacy. That is why conveyancing sits at the centre of AML supervision of Irish solicitors by the Law Society of Ireland - and why every fee earner in a conveyancing practice needs a working sense of what "suspicious" actually looks like.

A red flag is not proof of wrongdoing. Most flags have innocent explanations. The point is that a flag obliges you to stop, ask, and evidence the answer - and to escalate to your MLRO when the answer does not hold together. The examples below are hypothetical patterns, grouped the way they tend to appear in a real file. From 10 July 2027 the AMLR - Regulation (EU) 2024/1624 - sharpens several of the underlying rules, which are noted where relevant.

Red flags in the funding

Money is where most conveyancing risk lives. Watch for:

• Funds from third parties. The deposit arrives from an account in a different name - a relative, a company, an unexplained associate. Gifted deposits are common and often innocent, but the giver's identity and the reason for the gift belong on your file.
• Cash, or cash-adjacent behaviour. Remember the AMLR introduces an EU-wide 10,000 euro cap on cash payments in commercial transactions, and occasional cash transactions of 3,000 euro or more carry their own CDD trigger. A client probing how much can be paid in cash is itself a flag.
• Funds from multiple accounts or jurisdictions. A purchase price assembled from several sources, especially overseas accounts with no evident connection to the client, needs mapping - every source, evidenced.
• Last-minute changes of funder. The mortgage falls away and a private funder appears days before closing; or the balance arrives from an account you have never seen. Late substitution of funds is a classic layering pattern.
• A story that outruns the evidence. Income that does not plausibly support the purchase, savings with no history, or "business proceeds" from a business you cannot verify. Source-of-funds work means documents, not assurances.

Red flags in the parties

• Reluctance around identification. Delay, partial documents, or irritation at routine CDD from someone who has presumably bought property before.
• Distance with no explanation. A purchaser buying sight-unseen, far from any connection to the area, with no coherent reason.
• Corporate and trust structures. Companies are legitimate purchasers, but layered or cross-border structures demand beneficial-ownership work: identify the humans at 25 per cent or more, obtain your extract from the Register of Beneficial Ownership at rbo.gov.ie before the relationship begins, and report any discrepancy you find between the register and your own findings.
• The client who never appears. Instructions arriving only through an intermediary, with the true principal kept at arm's length, should prompt the question: who is my client, and who is really directing this purchase?
• Politically exposed persons. A PEP, their family member or close associate on either side of a transaction triggers enhanced due diligence, including source-of-wealth work and senior approval.

Red flags in the transaction itself

• Price that makes no sense. Significantly above or below market value with no explanation, or a price renegotiated at the last minute without commercial logic.
• Back-to-back or rapid resales. A property sold on quickly, particularly at a markedly different price, can be layering in progress.
• Indifference. A purchaser uninterested in survey, title conditions or price - the things genuine buyers care about - may care only about placing the money.
• Unusual urgency. Pressure to exchange and complete at a pace that squeezes out your checks, especially combined with any funding flag above.
• Aborted transactions with funds in your client account. A deal that collapses after money lands, followed by a request to return the funds - possibly to a different account - is a well-known laundering pattern in its own right.

What a red flag requires you to do

A flag is a fork in the road, not an automatic refusal:

1. Pause and ask. Put the question to the client plainly and record the answer.
2. Escalate. If the explanation is missing or unconvincing, it goes to your MLRO. That decision point - and its outcome - should be documented even when the conclusion is "resolved, proceed".
3. Report where suspicion remains. In Ireland, Suspicious Transaction Reports are dual-filed: to FIU Ireland via the goAML portal at fiu-ireland.ie and to the Revenue Commissioners via ROS.
4. Do not tip off. Nothing in your dealings with the client may reveal that a report has been made or is contemplated.
5. Decide about the retainer. Reporting and continuing to act, and reporting and withdrawing, are both possible outcomes; the decision needs care and a record.

What to do now

• Circulate a conveyancing-specific red-flag list to every fee earner and support staff member on property files - generic lists get ignored.
• Make source-of-funds evidence a file-opening requirement, not a completion-week scramble.
• Build the third-party-funds question into your standard client care process: who is paying, and why.
• Check your corporate-purchaser workflow: beneficial owners identified, RBO extract obtained before the relationship, discrepancies reported.
• Log every escalation to the MLRO, including the ones resolved without a report.
• Refresh training before 10 July 2027 so thresholds and duties reflect the AMLR, not the old rulebook.

Where CompliDesk fits

CompliDesk Ireland turns this discipline into workflow - source-of-funds prompts, beneficial-ownership checks and escalation records built into every matter file. For what a complete conveyancing CDD file should contain, see the CDD file checklist.