Real estate agencies across France are being required to implement a compliant LCB-FT (Lutte Contre le Blanchiment et le Financement du Terrorisme) system, aimed at preventing money laundering and the financing of terrorism, according to recent reports. These systems must be tailored to the specific operations, location, clientele, and type of properties each agency deals with. A generic approach is not acceptable; instead, each agency must create a risk mapping that identifies and classifies potential risks based on its unique circumstances. While agencies in a network may use a common framework, they must adapt it to their individual needs due to differences in local risks, client profiles, and property types. Key risk factors often include transactions involving politically exposed persons (PPEs), complex legal structures without clear justification, funds originating from high-risk countries, and operations conducted remotely. The risk mapping must be updated whenever an agency's operations or environment change. Alongside this mapping, internal procedures must be established to define how each risk will be addressed. These procedures should include the collection of specific documents, verification checks, and the designation of a responsible person for LCB-FT compliance. All employees must receive initial and ongoing training on these procedures, and records of this training must be kept for the duration of their employment and for five years after they leave. KYC (Know Your Customer) procedures are mandatory, requiring agencies to identify and verify a customer’s identity, as well as understand the nature of their transactions. This includes verifying the source of funds and ensuring it aligns with the customer’s financial profile. For companies, the agency must identify the legal entity, its representative, and the effective beneficial owners, who are natural persons holding more than 25% of the capital or voting rights, or who otherwise exert control. The process also involves tracing the full ownership chain to ensure transparency. Any inconsistencies in the financing of a transaction must be thoroughly explained and documented. For example, if a young student purchases property with cash, the agency must conduct additional checks to verify the source of the funds. If a transaction involves a PPE or a high-risk country, the checks must be more rigorous, especially regarding the origin of funds. If a person is under an asset freeze, the agency cannot accept funds from them, and the business relationship must be terminated with a report submitted to the DG Trésor. All checks must be recorded, with cross-referenced information and supporting documents retained. Tools like MyNotary can automate these checks by querying relevant databases and compiling reports that are attached to each client file. Each transaction is also assessed using a risk assessment sheet that compares the case with the agency’s risk mapping, assigns a risk level, and justifies the actions taken.