Risk-Based Approach Guidance for the Real Estate Sector - summary of the FATF public consultation

Publication details




26 July 2022 - The FATF held a public consultation on its draft Risk-Based Approach Guidance for the Real Estate Sector from 7 March until 22 April 2022.

Stakeholders were invited to provide comments and additional input to this draft as needed in line with their expertise and professional insights.

The FATF Secretariat received comments from 13 private sector representatives, including from sector specific professional associations, the legal profession, FinTech providers, as well as the Non-Profit Organisations (NPO) sector.

The feedback provided broadly supported the draft and its content with no major issues being raised regarding the scope of the Guidance, its objectives or drafting style.

The majority of comments and input focused on:

  • The need for greater clarity in Guidance regarding its applicability to the real estate sector, as well as related professions (lawyers, notaries and financial institutions);
  • Requesting FATF to ensure the further harmonisation of AML/CFT requirements so that the sector may operate with greater certainty across borders;
  • Calls for a de facto and more effective implementation of the FATF risk-based approach;
  • Calls for greater reach of FATF recommendations, namely the application of R22 and R23 to broader real estate activities such as property development, leasing and others, which are currently not directly targeted by the Standards.

The FATF Project Team tasked with updating and drafting the Guidance reviewed the draft document in line with the input received during public consultation. The great majority of contributions were included as suggested and as long as within the scope of the existing obligations.

The FATF thanks all stakeholders for their valuable and meaningful participation, as well as for all the time and effort devoted to this public consultation.