Last Updated on: 24nd July 2026 | Last Reviewed on: 24nd July 2026
Key takeaways at a glance
Who is covered: real estate agents, that is, persons who negotiate or act for a commission or fee in the sale or purchase of a plot, apartment or building, notified as a designated business under section 2(1)(sa) of the PMLA.
The trigger: an annual turnover of Rupees 20 lakh or more, under G.S.R. 798(E) of 28 December 2020, regardless of the agent’s registration status under a State RERA.
Governing laws: the PMLA, 2002 and the PML (Maintenance of Records) Rules, 2005; the DG Audit AML/CFT/CPF Guidelines for Real Estate Agents, 2023; the UAPA 1967 (Section 51A) and the WMD Act, 2005 (Section 12A).
Regulator: the Central Board of Indirect Taxes and Customs (CBIC), acting through its Directorate General of Audit (DG Audit). Reports go to the Financial Intelligence Unit India (FIU-IND); the Enforcement Directorate (ED) enforces the PMLA.
Core duties: registration with FIU-IND, an internal risk assessment, customer due diligence and KYC, beneficial owner identification, ongoing monitoring, cash and suspicious transaction reporting, five-year record-keeping and sanctions screening.
Real estate agents are reporting entities under the Prevention of Money-Laundering Act, 2002 once their annual turnover reaches Rupees 20 lakh or more, irrespective of whether they are registered with a State Real Estate Regulatory Authority. From that point, its AML, CFT and CPF duties flow from the PMLA, the PML (Maintenance of Records) Rules, 2005, the AML/CFT/CPF Guidelines for Real Estate Agents issued by the Directorate General of Audit, Section 51A of the UAPA, Section 12A of the WMD Act, and the FIU-IND reporting framework. The Central Board of Indirect Taxes and Customs, acting through the Directorate of General Audit, is the sectoral regulator, while prescribed reports are filed with FIU-IND.
The core instruments at a glance
Instrument | What it does for an agent |
PMLA, 2002 | The parent Act. Makes an agent a reporting entity and creates the core duties of CDD, record-keeping and reporting. |
PML (Maintenance of Records) Rules, 2005 | Set out what to report and when, how to identify customers and beneficial owners, and the duty to appoint officers. |
G.S.R. 798(E), 28 December 2020 | The notification that designates real estate agents and sets the Rupees 20 lakh annual turnover trigger. |
AML/CFT/CPF Guidelines for Real Estate Agents, 2023 (DG Audit) | The agent’s working rulebook, issued by the regulator, effective 29 November 2023. |
UAPA Section 51A and WMD Act Section 12A | Impose targeted financial sanctions for terrorism and proliferation financing, applied by every agent regardless of turnover. |
FATF Recommendations 22 and 23 | The international standards for DNFBPs that India’s real estate regime is built to meet, supported by the FATF real estate guidance of 2022. |
What counts as a real estate agent in India?
The AML legislative framework derives the meaning of a real estate agent from the Real Estate (Regulation and Development) Act, 2016 (RERA). A real estate agent is a person who negotiates or acts on behalf of one person in a transaction of transfer of a plot, apartment or building, for a commission, fee or any other charge, and includes a person who introduces two parties to each other for the sale or purchase of real estate. In practice, this covers property brokers, dealers and agencies, irrespective of whether they are registered with the State RERA.
What brings an agent within the anti-money laundering law is not any single deal but a monetary threshold: an annual turnover of Rupees 20 lakh or more. An agent below that turnover is not a reporting entity for the customer due diligence and reporting duties. However, it must still apply the sanctions screening obligations under section 51A and 12A of the UAPA and WMD Act, respectively, regardless of turnover and RERA registration.
Are real estate agents reporting entities under the PMLA?
Yes. By virtue of notification by G.S.R. 798(E) of 28 December 2020, issued under section 2(1)(wa) of the Prevention of Money-Laundering Act, 2002, real estate agents are brought within India’s AML, CFT and CPF framework. The notification classifies persons providing services in relation to the sale or purchase of real estate where they have an annual turnover of Rupees 20 lakh or more. As a result, such agents become persons carrying on a designated business or profession under section 2(1)(sa)of the PMLA and are subject to obligations applicable to reporting entities.
After becoming a reporting entity, the agent must register with the Director, FIU-IND and run a full AML programme. This places an agent in the same broad category of reporting entities that file with FIU-IND as banks, intermediaries and other financial institutions, scaled to the size and risk of the agency. It also connects the agent to the wider list of DNFBPs subject to the PMLA.
Supervisory authority for real estate agents in India
The regulator for real estate agents is the Central Board of Indirect Taxes and Customs, named in Rule 2(1)(fa)(iv) of the PMLR. The CBIC acts through its Directorate General of Audit, which was appointed as the Regulator on behalf of the CBIC by an office memorandum of the Commissioner (GST-Investigation) dated 22 November 2021. The Additional Director General, DG Audit, has also been appointed the Nodal Officer for the purposes of Section 51A of the UAPA and Section 12A of the WMD Act.
This is a separate supervisory line from the State Real Estate Regulatory Authorities under RERA. RERA registration governs how an agent may conduct property business; the PMLA duties, supervised by DG Audit, sit on top and apply by reference to turnover, not RERA status. The Financial Intelligence Unit – India receives the reports agents file, and the Enforcement Directorate investigates and prosecutes the offence of money laundering under the PMLA.
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AML Regulatory Requirements for Real Estate Agents in India
The law governing the real estate agents is spread across multiple legislative and regulatory instruments rather than a single statute. It is best understood as a layered framework comprising the core legislation, the overarching obligations, the sectoral regulator and its guidelines, the miscellaneous official reports, the international standards, and the allied laws that together shape the AML, CFT and CPF framework obligations applicable to real estate agents.
Core Legislation
The primary statutes and rules that create the AML, CFT and CPF obligations, grouped into three sets.
AML Legislation
Prevention of Money-Laundering Act, 2002 (PMLA)
India’s principal anti–money laundering statute and the foundation of a real estate agent’s reporting obligations under the AML, CFT and CPF framework. It defines the offence of money laundering and establishes the obligations applicable to reporting entities, including customer due diligence under Section 11A and record-keeping under Section 12.
These requirements apply to agents once they become reporting entities by crossing the prescribed turnover threshold. Given that real estate transactions can involve high-value assets and a single deal can absorb a large amount, they may be used to disguise the origin of the proceeds and facilitate them through legitimate channels, which is why the Act reaches the agents who arrange those deals.
The PML (Maintenance of Records) Rules, 2005 (PMLR)
The procedural framework made under the PMLA that frames how reporting entities implement statutory obligations. For real estate agents, the Rules specify the reporting requirements and timelines (Rule 3 and Rule 8), customers and beneficial ownership identification requirements (Rule 9), and the duty to appoint a Principal Officer and Designated Director (Rule 7). The PMLR has been amended through 31 Gazette notifications and orders to strengthen the framework.
Read the table below as a legal history timeline; G.S.R. 798(E) of 28 December 2020 is the main notification that brought real estate agents into the regime.
The 31 PMLR amendment notifications, in date order:
Gazette notification and date | Key change or rule touched |
G.S.R. 389(E), 24 May 2007 | The very first amendment to the 2005 Rules. It substituted suspicious transaction definition to reach dealings lacking economic rationale or bona fide purpose and those pointing to terrorism financing, revised Rule 3 to capture cash dealings in forged or counterfeit currency, substituted Rule 8 on how information reaches the Director, and reduced Rule 9’s requirement from three certified copies to one. |
G.S.R. 816(E), 12 November 2009 | It introduced the non-profit organisation and Regulator definitions, revised the suspicious transaction meaning, and brought in reporting of NPO receipts above Rupees 10 lakh. It set a ten-year record retention period under Rule 6 and revised Rule 9 around identifying the beneficial owner, ongoing due diligence, a prohibition on anonymous accounts and a Client Identification Programme. |
G.S.R. 76(E), 12 February 2010 | Amended Rules 3, 4, 5, 7 and 9 to strengthen the record keeping and the reporting cross references, and, most significantly, added the first Explanation in Rule 9(1A) defining the beneficial owner as the natural person who ultimately owns or controls a client or on whose behalf a transaction is carried out. |
G.S.R. 508(E), 16 June 2010 | Revised Rules 2, 9 and 10, the provisions on definitions, customer due diligence and record keeping, changing how a reporting entity identifies customers and retaining documents. |
G.S.R. 980(E), 16 December 2010 | Inserted the small-account regime. It defined the Designated Officer and the small account, added the NREGA job card and the Aadhaar letter to the officially valid documents in Rule 2, and inserted Rule 9(2A) on how such an account is opened and monitored. |
G.S.R. 481(E), 24 June 2011 | It amended Rule 1 to condense the long 2005 name into the Prevention of Money Laundering (Maintenance of Records) Rules, the PMLR shorthand used ever since. |
G.S.R. 576(E), 27 August 2013 | Amended Rules 2 and 3 and added provisions after Rule 10, adjusting definitions, the cash and suspicious transaction reporting duties and the record framework to align more closely with the reporting obligations. |
G.S.R. 288(E), 15 April 2015 | Revised the Rule 2 definitions. Since definitions determine who and what the operative rules reach, the change carried through the framework and began a run of 2015 updates. |
G.S.R. 544(E), 7 July 2015 | Amended Rules 2, 9, 10 and Inserted Rule 9A on definitions, customer due diligence and record registry, refining how a reporting entity identifies customers and what it retains. |
G.S.R. 730(E), 22 September 2015 | Amended Rules 2 and 7, the definitions and the requirement for a Principal Officer and an internal reporting mechanism, tightening the governance side and the reporting function. |
G.S.R. 882(E), 18 November 2015 | Updated the definitions and reporting provisions, altering how key terms are read and how transactions reach the FIU, and closing the 2015 cluster of amendments. |
G.S.R. 347(E), 12 April 2017 | Amended Rule 2 and inserted Rule 9B, bringing the Central KYC Records Registry into the Rules, creating the duty to file customer KYC records centrally and the basis to reuse them, the structural change that underpins today’s CKYCR. |
G.S.R. 538(E), 1 June 2017 | Amended Rules 2 and 9 to recognise Aadhaar into customer due diligence, setting out Aadhaar based identification and authentication in KYC, an approach later reshaped by the Supreme Court’s Aadhaar ruling. |
G.S.R. 1038(E), 21 August 2017 | Revisited the Rule 2 definitions, adjusting the defined terms that govern how the operative rules apply, one of several definition updates during 2017. |
G.S.R. 1318(E), 23 October 2017 | A further 2017 revision of the Rule 2 definitions, keeping the defined terms current as the framework developed. |
G.S.R. 456(E), 16 May 2018 | Updated the definitions and customer due diligence provisions, refining who is covered and how customers are identified and verified, in the continuing adjustment of the CDD framework. |
G.S.R. 1078(E), 31 October 2018 | Substituted the timeline of filing of electronic records of client’s CDD to CKYC registry from 3 days to 10 days under Rule 9. |
G.S.R. 108(E), 13 February 2019 | Revised Rules 2 and 9 on definitions and customer due diligence in the wake of the legislative changes to Aadhaar use, changing the options open to a reporting entity for verifying identity. |
G.S.R. 381(E), 28 May 2019 | Amended Rule 9, refining the identification and verification process and the ways for confirming a customer’s identity, part of the post-Aadhaar reshaping of CDD. |
G.S.R. 582(E), 19 August 2019 | Revised Rules 2 and 9 and inserted annexure after Rule 11 definitions, digital KYC process and the supporting information and record keeping provisions, one of the broader amendments of 2019. |
G.S.R. 669(E), 18 September 2019 | Further Inserted definition and provision under Rules 2 and 9, adding the depository receipt and the CDD and identification of beneficial owner dealing with depository receipt. |
G.S.R. 840(E), 13 November 2019 | Amended Rule 9 with further refinements to the identification and verification requirements, closing the 2019 sequence of CDD changes. |
G.S.R. 228(E), 31 March 2020 | Amended the operational timeline of the small accountants for the year 2020 and further as notified by the central government. |
G.S.R. 251(E), 13 April 2020 | Revised Rule 8, which governs how transaction reports are furnished to the FIU, adjusting the manner and content of what a reporting entity submits. |
G.S.R. 254(E), 16 April 2020 | A second Rule 8 amendment within days of the previous one, together tightening the reporting provisions and how reports reach the FIU. |
G.S.R. 798(E), 28 December 2020 | The defining notification for this sector. It designated real estate agents as persons carrying on a designated business or profession where their annual turnover is Rupees 20 lakh or more, and, read with G.S.R. 799(E) and 800(E) of the same day, named the CBIC as regulator, extending the regime well beyond banks to reach property brokers. |
G.S.R. 575(E), 13 July 2022 | Added the International Financial Services Centre definition and a tailored beneficial owner rule for entities located in an IFSC, inserted an IFSC proviso to Rule 9A on the CKYCR, aligning the Rules with the GIFT City framework. |
S.O. 1074(E), 7 March 2023 | It added definitions of politically exposed persons, non-profit organisations and group and a Rule 3A duty for group-wide AML policies, and, most importantly for an agent, cut the company beneficial ownership threshold from 25 to 10 per cent, with a matching change to Rule 9(3)(e). |
G.S.R. 652(E), 4 September 2023 | It required the Principal Officer to be at management level, cut the partnership beneficial ownership threshold from 15 to 10 per cent, added an Explanation of control, obliged trustees to disclose their status, and obligated the results of any Rule 3 and Rule 9 analysis to kept among the records of a reporting entity. |
G.S.R. 745(E), 17 October 2023 | Amended Rules 2, 3, 8 and 9 together, covering definitions, the reporting duties and tipping- off, refined several operative provisions in one notification and rounding off the 2023 changes. |
G.S.R. 419(E), 19 July 2024 | Revised Rule 9(1C) on the KYC Identifier and set a seven-day deadline to update a CKYCR record after any change, added a duty to revive the updated record, and amended Rule 9A(2)(g) on filing, retrieving and using registry records, tightening how current central KYC data is maintained. |
The PML (Manner of Receiving the Records Authenticated Outside India) Rules, 2005
A short set of rules on accepting customer records authenticated outside India. For an agent, they come into force when a buyer is a non-resident Indian, a foreign national or an overseas company, and the identity and ownership documents relied on for a property purchase were executed and certified abroad rather than in India.
CFT Legislation
The Unlawful Activities (Prevention) Act, 1967 (UAPA)
The counter terrorism legislation of India. Its Section 51A obliges an agent to screen customers and beneficial owners against the designated terrorism lists and to freeze, without delay, the funds and assets of any listed person or entity. Unlike the PMLA reporting obligations, the screening requirements under this section apply to every real estate agent, irrespective of their turnover.
Procedure for implementation of Section 51A of the UAPA (order dated 2 February 2021; corrigendum dated 15 March 2023)
The detailed procedure an agent follows to give effect to Section 51A when a client matches a designated list. DG Audit has translated it into a real estate-specific standard operating procedure dated December 2023, so an agent has a significant screen, hold and report workflow rather than only the bare statutory order.
CPF Legislation
The Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005 (WMD Act)
India’s principal proliferation financing statute. Section 12A of the Act supplies the legal basis for targeted financial sanctions aimed at the financing of weapons of mass destruction, and it reaches a real estate agent alongside financial institutions, since property can be used to hold and move value for a sanctioned network just as readily as a bank account.
Procedure for implementation of Section 12A of the WMD Act (dated 1 September 2023)
The implementation procedure for Section 12A, which replicates the Section 51A screening and freezing steps but for proliferation financing designated individuals and institutions. For an agent, it runs through the same DG Audit sanctions screening SOP, so terrorism and proliferation lists are both checked in one workflow before a customer is onboarded.
The WMD and their Delivery Systems (Prohibition of Unlawful Activities) Implementation Rules, 2016
The subordinate rules that put the WMD Act into operation and support the designated list, freezing and reporting actions an agent must be able to carry out the moment a proliferation financing designation match arises in a transaction.
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Overarching Obligations
The shared national guidelines that an agent is subjected to once it is a reporting entity.
CERSAI Central KYC Records Registry (CKYCR) Operating Guidelines, 2025
India’s central repository for customer KYC records. They set out the guidelines under which reporting entities, including agents, upload verified KYC records and retrieve existing records submitted by other reporting entities. It is useful for real estate agents as it helps identify beneficial ownership, cross-check identity data right at onboarding, and keeps KYC consistent across the system.
FINnet 2.0 reporting formats (2024) and the FINGate 2.0 reports manual (June 2023)
The instruments governing the registration, reporting and use of the FIU-IND reporting portal. They establish the procedure for enrolment as a reporting entity and the submission of the reports under PMLA. The first practical step for real estate agents is to register on the portal once the turnover threshold is crossed and the agent becomes subject to the regime.
Section 11A Aadhar authentication procedure for non-banking entities
The procedure by which an entity other than a banking company applies for permission to use Aadhaar authentication services for KYC. It matters to agents because they are exactly the non-banking reporting entities that must obtain that approval before verifying a buyer or seller’s identity through Aadhaar.
Sectoral Guidelines
The regulator and its agent-specific instruments. This is the layer that gives the real estate regime its own character, because the rulebook and the supervision come from the CBIC through DG Audit, a line quite separate from the State RERA authorities.
AML/CFT/CPF Guidelines for Dealers in Precious Metals and Precious Stones, 2023 (effective 29 November 2023)
The agent’s working rulebook, and the most important instrument on this page. Issued by the Directorate General of Audit under the PMLA, UAPA and WMD Act. Effective from 29 November 2023, it defines a real estate agent by reference to RERA with the Rupees 20 lakh turnover threshold and sets out the operational requirements for risk assessment, policies and procedures, customer due diligence, officially valid documents, cash and suspicious transaction reporting, record-keeping, staff training, and the implementation of Sections 51A of the UAPA and 12A of the WMD Act.
SOP for screening under Section 51A of the UAPA and Section 12A of the WMD Act by DPMS (4 December 2023)
A real estate-specific standard operating procedure from DG Audit for screening buyers, sellers and beneficial owners against the United Nations and Government of India sanction lists, and for acting on a match. It converts the sanctions duty into concrete steps an agent can run before a transaction completes.
Notification designating dealers in precious metals and stones as DNFBPs, G.S.R. 799(E) (28 December 2020)
The notification that brings real estate agents within the definition of reporting entity under section 2(1)(sa) of the PMLA on reaching the Rupees 20 lakh annual turnover. Read together with G.S.R. 800(E) issued on the same date, designates the CBIC as the regulator of the real estate agents under Rule 2(1)(fa) of the PMLA rules.
Miscellaneous official Reports and Guidance
Official reports and guidance that sit outside the binding rulebook but shape how an agent reads its risk and its duties.
FIU-IND Annual Report 2024-25
The FIU-IND’s 2024-25 annual report is based on the received, analysed, and disseminated account information. For an agent, it is a useful document for understanding how DNFBP reporting is growing and where FIU-IND is focusing, so an agent can benchmark its own reporting against the wider sector.
Directorate of Enforcement Annual Report 2025-26
The Enforcement Directorate’s annual report details investigations, provisional attachments and prosecutions under the PMLA. It illustrates how the enforcement framework operates in practice, including attachment and confiscation of properties identified as the proceeds of crime.
FIU-IND and its Core Functions and FAQs
A question-and-answer instrument explaining the role of FIU-IND does reporting obligations of the reporting entities. It is a practical first primer for an agent that has just crossed the turnover threshold and is standing up its reporting function by enrolling on FINnet 2.0 for the first time.
MHA National Counter-Terrorism Policy and Strategy
The Ministry of Home Affairs statement of national counter terrorism policy and strategy. It frames the wider intent behind the CFT duties that Section 51A places on an agent and explains why sanctions screening applies whatever the agent‘s turnover.
International Standards
The International benchmarks India is measured against, and the sources an agent can use to calibrate a risk-based approach to property transactions.
FATF Recommendations
The global benchmark for AML, CFT and CPF legal adaptation of all nations. Recommendations 22 and 23 extend customer due diligence and suspicious transaction reporting obligations to real estate agents, along with all the other DNFBPs. The recommendations were last updated in 2026, and India’s AML, CFT and CPF framework is developed according to them.
FATF Mutual Evaluation Report on India, 2024 and Executive Summary
The 2024 FATF mutual evaluation report, together with its executive summary. It assesses the effectiveness of India’s AML, CFT and CPF framework, examines the practical implementation, supervision and reporting across the DNFBPs, identifies real estate as a medium-high risk sector, and highlights the area where framework is expected to strengthen further.
FATF Risk-Based Approach Guidance for the Real Estate Sector (2022)
Sector-specific FATF guidance on identifying and managing money laundering risk in property transactions. It is an off-the-rack template for an agent’s internal risk assessment, covering the red flags, the role of the agents involved and the risk-based controls a real estate business should undertake.
Allied Laws
The wider body of law that defines the offences, proceeds of crime and the enforcement machinery around money laundering. An agent does not administer these Acts, but they shape the risk it must assess and the conduct it may need to report.
The allied laws that most often bear on an agent’s risk are the following:
The Real Estate (Regulation and Development) Act, 2016: Regulates the registration, duties and conduct of real estate agents. It determines who is recognised as a real estate agent and establishes the regulatory framework within which AML CFT and CPF obligations operate.
The Bharatiya Nyaya Sanhita, 2023 and The Bharatiya Nagarik Suraksha Sanhita, 2023: the successors to the Indian Penal Code and the Code of Criminal Procedure respectively, defining the crimes that generate proceeds encountered in property transactions and providing the procedure that supports the enforcement of statute.
The Companies Act, 2013: Assists in identifying corporate customers, beneficial ownership and company structures during customer due diligence.
The Foreign Exchange Management Act, 1999: It governs the acquisition and transfer of immovable property by non-residents and regulates foreign exchange aspects of the property transactions.
The Benami Transactions (Prohibition) Act, 1988: Prohibits property being held in the name of another person and is particularly relevant when verifying ownership structures and the ultimate beneficial owner.
The Prevention of Corruption Act, 1988, The Narcotic Drugs and Psychotropic Substances Act, 1985, The Fugitive Economic Offenders Act, 2018, The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015, The Foreign Contribution (Regulation) Act, 2010, The Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974, The Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976, The Arms Act, 1959, The Chemical Weapons Convention Act, 2000 and The Central Vigilance Commission Act, 2003. These legislations provide a wider context within which real estate agents assess client risk, identify red flags and apply the requirements of the PMLA framework.
Core AML/CFT/CPF Obligations for Real Estate Agents in India
Across that framework, the regulations require a real estate agent to do the following. This article keeps each at the level required by law; a compliance requirements guide explains how to do each.
- Register with FIU-IND. Enrol with the Financial Intelligence Unit India on the FINnet 2.0 / FINGate 2.0 portal once the agent’s annual turnover reaches Rupees 20 lakh or above, so the agent can file its reports.
- Appoint officers. Appoint a Designated Director and a management-level Principal Officer under Rule 7 of the PMLR. The same person cannot hold both roles, and both are to be informed to FIU-IND.
- Conduct the internal risk assessment. Assess money laundering, terror financing and proliferation financing risk across clients, deal types, delivery channels and geographies, drawing on the FATF real estate guidance, and keep it current.
- Document AML policy, controls and procedures. Adopt an approved policy that turns the risk assessment into the agency’s operating procedures, as required by the DG Audit Guidelines.
- Customer identification and CDD. Identify and verify every client and the beneficial owner (a controlling interest of more than 10 per cent for a company or partnership, and more than 15 per cent for an unincorporated association or body of individuals), with enhanced due diligence for politically exposed persons and high-risk clients, under Section 11A of the PMLA, Rule 9 of the PMLR and the DG Audit Guidelines, using the officially valid documents the Guidelines list.
- Ongoing monitoring and periodic update. Monitor transactions on an ongoing basis, and refresh KYC at least once every 2, 8 and 10 years for high, medium and low-risk clients respectively. Review each client’s risk categorisation at least once every six months and decide whether enhanced due diligence is required.
- Sanctions screening. Screen clients and beneficial owners against the designated lists issued under Section 51A of the UAPA and Section 12A of the WMD Act. When a confirmed match is identified, freeze the funds and report the match. Verify the relevant UNSC and domestic designated lists on a daily basis, following the DG Audit screening SOP. This duty applies to every agent, whatever its turnover.
- Regulatory reporting. File cash transaction reports for cash of more than Rupees 10 lakh and for series of connected cash transactions, reports on cash transactions involving counterfeit currency, forged valuable security or forged documents, and suspicious transaction reports of any value, including attempted transactions, under Rule 3 and Rule 8 of the PMLR. Cash and counterfeit or forged document reports are filed monthly, by the 15th day of the succeeding month; a suspicious transaction report is filed promptly once the Principal Officer is satisfied that the transaction is suspicious.
- Record management, CKYCR and FINnet 2.0. Keep transaction records for five years from the date of the transaction and keep identity records and business correspondence for five years after the business relationship ends, under Section 12 of the PMLA. Upload customer KYC records to the Central KYC Records Registry under Rule 9A, reuse an existing record where applicable, and file all prescribed reports through FINnet 2.0.
- Training and awareness. Train staff and sub-agents by role to apply the controls and recognise the red flags of property-based laundering.
- Independent testing and audit. Test the programme through internal audit, compliance assurance or independent review, and close every finding.
What this article does not cover
This article explains the laws and regulatory instruments that apply to real estate agents. It intends to explain India’s compliance standards for AML, CFT and CPF rather than serve as a control-by-control compliance manual. Accordingly, it does not restate the RERA registration and conduct rules that govern the property business itself, except where they define who is an real estate agent. For implementation, an agent separately documents client acceptance, KYC and CDD procedures, beneficial owner identification, sanctions screening, transaction monitoring, suspicious transaction reporting, staff training, audit testing and management reporting. Those controls are the subject of the companion compliance guide.
For an overview of the wider legislative framework, see AML laws and regulations in India, and to understand how real estate agents sit alongside the other designated businesses and professions, use the parent overview, AML laws and regulations for DNFBPs in India, which explains the framework applicable to all designated sectors.
From regulation to compliance: your next step
Knowing the law is only step one. These obligations become effective only when they are implemented through practical measures of risk assessment, policy and procedure, customer due diligence, monitoring, screening, reporting, staff training and independent audit. Because even a single high-value property deal can carry significant laundering risk, agencies are placed to establish their compliance before reaching the prescribed turnover threshold rather than after it. A good starting point is to understand the three stages of money laundering and how the sanctions screening process works.
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Frequently Asked Questions
When a person is engaged in providing real estate services and has annual turnover that reaches Rupees 20 lakh or above, they are counted as a designated business or profession under G.S.R. 798(E) of 28 December 2020, obligating them to register with FIU-IND under PMLA.
The trigger is the annual turnover of the agency, set at Rupees 20 lakh or above and not the value of any one property transaction. The value of a deal matters separately for reporting: once an agent is a reporting entity, a cash transaction of more than Rupees 10 lakh or linked transactions must be reported.
No. A real estate agent’s AML, CFT and CPF obligations arise on reaching the prescribed turnover threshold of rupees 20lakh or more, not on registration with RERA. The PMLA framework applies based on the turnover threshold, irrespective of the agent’s RERA registration status.
The Central Board of Indirect Taxes and Customs, acting through its Directorate General of Audit, which was appointed the Regulator in November 2021 and issues the AML/CFT/CPF Guidelines for agents. Reports are filed with the Financial Intelligence Unit – India, and the Enforcement Directorate investigates and prosecutes the offence of money laundering.
Property transaction reports for transactions of immovable properties, Cash transaction reports for cash of more than Rupees 10 lakh and for linked ones complied to the same amount, reports on cash transactions involving counterfeit currency, forged valuable security or forged documents, and suspicious transaction reports of any value, including attempted transactions.
Yes. The sanctions screening duties under Section 51A of the UAPA and Section 12A of the WMD Act apply to every real estate agent, irrespective of annual turnover or RERA registration. Only the reporting entity duties, such as registration and prescribed transaction reporting, initiate when the Rupees 20 lakh turnover is reached.
According to the Notification G.S.R. 798 (E), persons involved in providing services related to the sale and purchase of real estate are real estate agents for AML, CFT and CPF statutes. Whicc in everyday terms, means builders, developers and all other intermediaries. Yet when in doubt about your role, confirm your position with a qualified professional.
Official sources and review
Last reviewed: July 2026. This guide is grounded in the following primary official sources, linked to their official source where available.
- Prevention of Money-Laundering (Maintenance of Records) Rules, 2005.
Why work with AML India
AML India helps real estate agents meet their PMLA and DG Audit obligations, from FIU-IND registration and risk assessment to CDD, screening, monitoring, reporting, staff training and independent review.
Industries we serve: Real Estate Agents and Property Brokers, Dealers in Precious Metals and Stones, Trust and Company Service Providers, Chartered Accountants, Company Secretaries and Cost and Management Accountants, Virtual Asset Service Providers, Casinos and the Gaming Sector, and Banks, Financial Institutions and IFSC and GIFT City entities
About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is a Chartered Accountant with more than 26 years of experience in governance, risk, and compliance. He helps companies with end-to-end AML compliance services, from conducting Enterprise- Wide Risk Assessments to implementing the robust AML Compliance framework. He has played a pivotal role as a functional expert in developing and implementing RegTech solutions for streamlined compliance.
Reach Out to Pathik
