AML checks for estate agents in Cyprus: who to check, when and what to keep

Published on 20 October 2026

House icon with a check mark, linked to client and document icons and to the flag of Cyprus

Cyprus recorded 18,114 property sales contracts in 2025, 15% more than the year before, according to the Department of Lands and Surveys (Cyprus Mail). Between January and July 2026, 41.3% of the contracts filed were signed by non-Cypriot buyers (Cyprus Mail).

Behind each of those sales, the estate agent has client checks to run. This article sums up what Cyprus’s AML law, Law 188(I)/2007, asks of agents: who to check, when, what to keep on file, and what changes when the EU AML Regulation applies in July 2027.

Estate agents are obliged entities

Section 2A of Law 188(I)/2007 lists estate agents among the obliged entities, the professionals who must apply anti-money laundering measures. This covers the sales and purchases they act in, and lettings where the monthly rent reaches or exceeds €10,000.

The law names the Real Estate Agents Registration Council as their AML supervisor (section 59). A bill put to public consultation in January 2026 would move this supervision to the Tax Commissioner and extend the obligations to professionals who buy or sell property in the course of business, which would bring developers selling their own units into scope.

Who to check

Customer due diligence starts with identifying the client and verifying their identity from reliable, independent sources (section 61(1)(α)). On a property sale, that means:

The buyer, or buyers. Each person signing, and the beneficial owner when someone acts on behalf of another person.
The people behind a company. When the client is a company, the agent identifies its beneficial owners and takes reasonable measures to understand who owns and controls it (section 61(1)(β)). If the company is on a beneficial ownership register, the agent keeps proof of registration or an extract of the register (section 62(1)).
The seller. Cyprus’s law refers to the agent’s client. FATF standards go further: the Interpretive Note to Recommendation 22 expects estate agents to apply due diligence to both the purchaser and the vendor.

In practice, each check includes screening the person or company against sanctions lists, politically exposed persons (PEP) lists and adverse media. Sanctions matter directly for property: under Regulation (EU) No 269/2014, the funds and economic resources of listed persons are frozen, and economic resources include immovable property.

When: before the transaction

The identity of the client and of the beneficial owner is verified before the business relationship starts or the transaction is carried out (section 62(1)), not at completion. For a company buyer, the ownership structure is usually the document that takes longest to obtain, so it pays to ask for it early.

Section 62(2) allows one exception. Where the risk of money laundering is low and it is needed to avoid interrupting business, verification can be completed while the relationship is being set up. It must then be finished as soon as possible after the first contact.

The obligation does not end at signing. For an ongoing business relationship, such as a landlord whose property you manage, a developer you work with or an investor who comes back, due diligence includes ongoing monitoring and keeping client information up to date (section 61(1)(δ)).

What to keep, and for how long

Customer due diligence documents and transaction records are kept for five years after the business relationship ends or after the date of the occasional transaction (section 68(1)).

The law sets the period. What makes a record usable is good practice: a record that still holds up years later shows:

who was checked, and when;
which sources were searched;
what came up;
what was decided, and why.

A closed browser tab or an undated screenshot shows none of this.

What changes on 10 July 2027

Regulation (EU) 2024/1624, the EU AML Regulation, applies in every member state from 10 July 2027. For estate agents, four points stand out:

Scope. It covers estate agents and other real estate professionals acting as intermediaries, including lettings with a monthly rent of at least €10,000 (Article 3(3)(d)).
Timing. Estate agents verify identity after the seller or lessor accepts an offer, and in all cases before any funds or property are transferred (Article 23(1)).
Sanctions and PEPs. Due diligence explicitly includes checking whether the customer or its beneficial owners are subject to targeted financial sanctions, including whether sanctioned persons control a company or hold more than 50% of it, and whether they are politically exposed persons, family members or close associates (Article 20(1)(d) and (g)).
Cash. Cash payments for goods and services are capped at €10,000 across the EU, and lower national limits remain possible (Article 80).

A checklist to keep at hand

We put these points into a six-page checklist, Before you sign, with the legal reference for each step. It is a practical summary, not legal advice: your own risk assessment and your supervisor’s guidance come first.

So Comply covers the screening part: sanctions lists, PEP lists and adverse media, with a dated report for each check and your decision recorded alongside it. See how it works for estate agents in Cyprus.