Property management companies and AML: where your duties sit

Property management is the corner of the property sector where AML duties are most often misunderstood. You are not selling houses, you rarely handle purchase deposits, and your day is filled with service charges, maintenance contractors and management agreements — so it is tempting to assume the AML rulebook belongs to the sales side of the industry. It does not. PSRA-licensed property management firms are designated persons under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, and from 10 July 2027 the EU's AML Regulation (the AMLR, Regulation (EU) 2024/1624) becomes the substantive rulebook you are measured against.

This post maps where your duties actually sit — and where they will sit after July 2027.

Who is your AML supervisor?

The PSRA — the Property Services Regulatory Authority — is both your licensing body under the Property Services (Regulation) Act 2011 and your AML competent authority. It supervises estate agents, letting agents, auctioneers and property management firms alike. That continues after the AMLR applies: the AMLR changes the rules, not the supervisor. Irish law calls your firm a "designated person"; the AMLR uses "obliged entity". Both describe you.

Who is your client for CDD purposes?

This is the question that decides most of your AML workload. A property management firm's clients are typically the parties it contracts with under management agreements — often companies rather than individuals. That makes your customer due diligence heavier than a typical sales agency's, not lighter, because corporate clients bring beneficial-ownership work:

• Identify and verify the client entity — name, registered details, and the natural persons authorised to act for it. Company details can be checked against the Companies Registration Office.
• Identify beneficial owners. Under the AMLR the harmonised test is ownership or control of 25% or more, direct or indirect. The Commission may later set a lower threshold — 15% or lower — for high-risk sectors by delegated act, following a review due by 2029, but 25% is the rule to build for now.
• Obtain an RBO extract before the relationship starts. Since April 2021, designated persons must obtain an extract from the Register of Beneficial Ownership before entering a new business relationship with a company, and must report discrepancies between the register and what CDD reveals. Access for designated persons is arranged via the BEN3A1 form, and extracts cost a flat €2.50 each. Keep the extract and your comparison note on file.

For individual landlord clients, standard identification and verification applies, with a risk rating recorded for each.

Does the lettings side change under the AMLR?

If your firm also carries out letting work, note that the AMLR expressly brings letting activity into scope for tenancies with a monthly rent of €10,000 or more. Most Irish residential lettings sit nowhere near that figure, but high-value corporate lets and some commercial arrangements do. Irish letting agents already operate under PSRA AML supervision, so the practical point is narrower: make sure your procedures recognise the €10,000-a-month marker and apply full CDD to those tenancies without debate.

Two other AMLR numbers matter for any firm that touches money: the CDD threshold for occasional transactions drops from €15,000 to €10,000, occasional cash transactions of €3,000 or more trigger limited CDD, and an EU-wide €10,000 cap applies to cash payments in commercial transactions. If a tenant or client ever offers significant cash — for arrears, deposits or fees — your payment policy needs an answer written down in advance.

What does ongoing monitoring look like in property management?

Management relationships run for years, which makes them exactly the kind of relationship where CDD quietly goes stale. Ongoing monitoring for a property management firm means:

• Keeping client and beneficial-ownership information current — directors change, shareholdings change, and a five-year-old RBO extract tells you little.
• Watching for unusual payment behaviour: third parties settling another party's obligations, overpayments followed by refund requests, or funds arriving from unconnected accounts.
• Escalating suspicion to your MLRO, and where a report is warranted, dual-reporting: to FIU Ireland via the goAML portal and to the Revenue Commissioners via ROS.

From 10 July 2027 the AMLR also prescribes compliance roles — a board-level compliance manager and a compliance officer of sufficiently high standing — and requires records to be retained for 5 years and then deleted. Long-running management relationships make that retention-and-deletion discipline harder than it sounds, so build it into your systems rather than your good intentions.

What to do now

1. List your current clients and confirm each file holds identification, verification and a recorded risk rating.
2. For every corporate client, check you hold beneficial-ownership information and an RBO extract with a discrepancy note.
3. Write a cash policy that respects the €10,000 cap and the €3,000 occasional-cash CDD trigger.
4. Flag any tenancy at or near €10,000 monthly rent for full CDD treatment.
5. Refresh your business-wide risk assessment to describe your management portfolio as it is today.
6. Assign the compliance manager and compliance officer roles ahead of 10 July 2027, and record the designation.
7. Set review dates so long-running client files are re-checked on a schedule, not on memory.

Where CompliDesk fits

CompliDesk Ireland is built for exactly this workload — corporate CDD, RBO extract evidence, risk ratings and scheduled reviews in one place, keyed to the AMLR from day one. For the full picture of what changes in 2027, start with our AMLR explainer.