AML/CFT obligations for real estate agents in Algeria (2026)

In Algeria as elsewhere, property remains one of the favourite investments for those seeking to give criminal proceeds a legitimate appearance. A property stores significant value; it can be resold, rented out and passed on. Its price can be understated or overstated, and the real buyer can hide behind a company or a relative. The real estate agent, who brings sellers and buyers together and knows market prices, is often the first professional able to spot an anomaly. The AML/CFT obligations for real estate agents make them a key link in prevention.

The stakes are all the higher since Algeria left the FATF grey list on 19 June 2026, and the next mutual evaluation, expected around 2029, will measure the real effectiveness of controls, profession by profession. The sectoral risk assessment published by the Ministry of Housing, Urban Planning and the City in June 2025 rates the sector's vulnerability as high. Since the May 2025 order, agencies have a detailed framework: the task now is to apply it and be able to prove it.

1. Applicable texts and supervisory authority

Law No. 05-01 of 6 February 2005, substantially overhauled by Law No. 23-01 of 7 February 2023 (OJ No. 08 of 2023), lists real estate agents among designated non-financial businesses and professions (DNFBPs). As such, they are "obliged entities" required to apply preventive measures, including suspicious transaction reporting. Article 10 bis 3 of the law designates the Ministry of Housing, Urban Planning and the City as their supervisory authority. To understand the 2023 reform, read our article on Law 23-01 on money laundering in Algeria.

On the basis of Executive Decree No. 23-430 of 29 November 2023, which frames the duties of supervisory authorities, the minister issued the order of 21 May 2025, published in Official Journal No. 38 of 19 June 2025. It puts in place a regulation on preventing and combating money laundering, terrorist financing and proliferation financing for real estate agents. The ministry has also published the order, the sectoral risk assessment report and implementation guides on its website.

Two other texts complete the framework. Since 1 January 2025, Article 207 of the 2025 Finance Law requires real estate transactions involving built or unbuilt property to be settled by means other than cash, through banking and financial channels, with implementing arrangements to be set by regulation. Law No. 25-10 of 24 July 2025 provides for a national and sectoral risk assessment that is regularly updated and shared with obliged entities.

2. Key obligations

Risk classification

The agency assesses its risks by client, service, transaction, delivery channel and country or area, taking national assessments into account. This assessment is documented, updated after any significant event and made available to the supervisor (Art. 3 and 4 of the regulation). It rests on a written programme of policies, procedures and internal control, reviewed at least once a year (Art. 5). Measures are proportionate: enhanced due diligence for higher risks, simplified only for proven low risk and never where there is suspicion.

Customer due diligence and beneficial owners

Anonymous accounts or files, or those in obviously fictitious names, are prohibited. The client's identity, address, the nature of the relationship and, where relevant, the identity of any agent acting for the client are verified before the relationship begins or the transaction is carried out. Due diligence applies to every business relationship and every occasional transaction above two million dinars, including linked transactions, as well as whenever there is suspicion or doubt about identification, whatever the amount (Art. 11 and 12). For a legal person, the beneficial owner is first the natural person holding at least 20% of the capital or voting rights, then the person exercising control by other means, and failing that the senior managing official (Art. 15). If verification is impossible, the agency must refrain and consider a suspicious transaction report (Art. 20). Politically exposed persons require enhanced due diligence and senior management approval (Art. 21).

Suspicious transaction reports to the CTRF

The agency reports suspicious transactions to the CTRF, Algeria's financial intelligence unit within the Ministry of Finance, where possible before execution by suspending them, and immediately if already executed, then forwards any new information (Art. 23). The report is confidential and the client must never be informed; made in good faith, it exempts its author from administrative, civil and criminal liability (Art. 24 to 27). If due diligence would tip off the client, the agency does not carry it out and files a report directly (Art. 25).

Asset freezing and targeted financial sanctions

The regulation requires an automated system to screen clients and beneficial owners against the UN Security Council consolidated lists and the national list, at onboarding, for each transaction and without delay after each update. Any match triggers immediate blocking of the transaction, without prior notice, and notification of the CTRF and the competent authorities (Art. 35). Under the text, "immediately" means acting within 24 hours of the resolution's publication.

Record keeping

Due diligence documents, correspondence, analyses and transaction records are kept for at least five years after the end of the relationship or the execution of the transaction, so that transactions can be reconstructed and promptly provided to the authorities (Art. 22).

Training and internal organisation

The agency appoints at least one senior manager responsible for compliance, independent and acting as the CTRF's contact, and provides for independent internal audit, strict hiring standards and ongoing training (Art. 29). All staff must know how to report a suspicion to the compliance officer (Art. 31). An annual report is submitted to the supervisor within three months of the financial year-end (Art. 33). Our guide to the compliance function in Algeria helps structure this role.

3. Sector-specific typologies and red flags

• a buyer who insists on paying in cash, or offers part of the price "off the deed";
• a price well above or below market value, without explanation;
• a purchase by a newly formed company with no activity, or by a relative with no apparent means;
• a client who refuses to meet the agency, acts through an agent without reason or provides inconsistent documents;
• rapid, successive resales of the same property with unexplained capital gains;
• funding from third parties with no apparent link to the buyer, or from abroad without justification;
• a client showing little interest in the location or condition of the property, but in a hurry to close;
• a politically exposed person, or a relative, acquiring property out of line with known income.

4. Common mistakes

In real estate agencies, we see recurring gaps, which the findings of the ministry's sectoral report largely confirm:

• Relying on the notary or the bank: each assumes the other has checked, whereas the obligation rests on every obliged entity.
• No written identification procedure: a simple copy of an ID document, with no search for the beneficial owner.
• No risk self-assessment and no enhanced due diligence for high-risk clients.
• No designated compliance officer, and staff who do not know how to report a doubt.
• No suspicious transaction reporting procedure and no sanctions screening, although the regulation requires an automated system.
• Forgetting the annual report due to the supervisor.

5. How Hodemia Consulting supports real estate agents

With nearly twenty years of international compliance experience, at EY and then as Director of Regulatory & Compliance Services at KPMG Middle East, Fayçal Lounes helps agencies turn the 2025 regulation into simple routines:

• Compliance diagnostic (2 to 4 weeks): review of your files and procedures against the order of 21 May 2025. See our approach to the compliance diagnostic.
• AML/CFT programme implementation and KYC remediation: risk assessment, client forms, beneficial ownership procedure, reporting channel, sanctions screening, annual report template.
• Compliance & Ethics training (1 day): real estate red flags and case studies for sales staff.
• Leadership & Compliance seminar (2 days): for heads of agency networks.

Discover our training programmes or contact us.

Conclusion: a precise regulation, a burden of proof

With the order of 21 May 2025, the AML/CFT obligations for real estate agents are now detailed: risk assessment, due diligence above two million dinars, beneficial owners at the 20% threshold, reporting to the CTRF, automated sanctions screening, five-year record keeping and an annual report. Combined with the cash ban for real estate transactions, these rules make the sector less permeable to money laundering, provided they are applied day to day. Agencies that get organised now will be ready for ministry inspections and the FATF evaluation expected around 2029. For an overview, see our guide to AML/CFT compliance in Algeria.

Fayçal Lounes

Founder of Hodemia Consulting

Nearly 20 years of international experience in regulatory compliance, risk and governance (EY in Luxembourg, San Francisco and London; Director, Regulatory & Compliance Services at KPMG Middle East). Certified coach, trainer and academic.