AML isn’t new for PSRA-licensed firms. The rulebook is being replaced.

Your licensing body

The PSRA (Property Services Regulatory Authority) licenses estate agents, letting agents, auctioneers and property management firms under the Property Services (Regulation) Act 2011. Your licence is its to grant.

Your AML competent authority

The PSRA is also the AML competent authority for the property services sector. It monitors your anti-money-laundering compliance and can inspect your files — the same body that holds your licence.

Sales: CDD on vendors and purchasers

On the sales side, customer due diligence applies to both sides of the transaction — the vendor instructing you and the purchaser buying through you. Identity verification, beneficial-ownership checks on corporate parties and screening all need to be on file for each.

Lettings: the €10,000-a-month rent rule

Under the AMLR, letting agents are in scope for tenancies with a monthly rent of €10,000 or more. High-value lettings — commercial premises, prime residential — bring the lettings desk into your AML programme, with the same due diligence discipline as a sale.

Lower CDD thresholds

Customer due diligence for occasional transactions drops to €10,000, from €15,000. Occasional cash transactions of €3,000 or more trigger limited CDD — think deposits, booking fees and auction payments still settled in cash.

The €10,000 EU cash cap

A directly applicable, EU-wide limit of €10,000 on cash payments for commercial transactions — whether paid as a single operation or as a series of linked ones. Your staff need to recognise a linked series when they see one.

The 25% beneficial-ownership rule + RBO duties

A beneficial owner is anyone holding 25% or more, direct or indirect — harmonised EU-wide. Before taking on a corporate client you must obtain an RBO extract and report discrepancies between the register and what you find (Reg 20(3)(b), SI 110/2019).

Prescribed compliance roles

The AMLR requires a board-level compliance manager plus a compliance officer of sufficiently high standing — even in a small agency. From 10 July 2027 the compliance officer also becomes responsible for implementing targeted financial sanctions.

STR dual reporting stays

Suspicious Transaction Reports are dual-reported in Ireland: to FIU Ireland via the goAML portal, and to the Revenue Commissioners via ROS as an XML upload. Your MLRO must be registered on both.

Retain five years — then delete

The AMLR requires records to be retained for five years and then deleted. Keeping every closed file forever is no longer compliant; your agency needs a defensible deletion process too.

A structured onboarding flow for vendors and purchasers alike, with KYC and KYB identity verification through Didit — due diligence captured once, consistently, to the AMLR thresholds.

Automatic warnings inside your client and transaction flows at the €10,000 cash cap and the €3,000 occasional-cash CDD trigger — so the front desk catches it before it becomes a breach.

Screen clients and beneficial owners against the EU consolidated financial sanctions list, UN lists and PEP datasets via OpenSanctions — at onboarding and on an ongoing basis.

A guided before-new-client workflow for corporate vendors and purchasers: obtain the RBO extract, store it, record the comparison against what the client told you, and log the discrepancy decision.

Generate a Business-Wide Risk Assessment and AMLR policy pack mapped to Regulation (EU) 2024/1624 — written for a small property services firm, not a bank, including the prescribed compliance-role designations.

Build the STR record, export goAML-compatible XML for upload to goAML and Revenue ROS, and track both submission dates and acknowledgements. CompliDesk prepares and records — your MLRO files.

Every compliance action sits on an audit trail, with a staff training log alongside. When the PSRA asks to see your AML file, you can show your work — organised, dated and in one place.