Compliance checks in the deal: anti-money laundering and prices
Checks on every sale, each at its own step.
EASYRE® has anti-money laundering checks to sign off at offer, preliminary contract and notarial deed.
Alongside the checks sit the price review queue, where offers wait before acceptance, and role-based access. For owners selling a real estate portfolio in Italy unit by unit through multiple brokers and estate agents, and for those who answer for the checks: in the SGR (Italian asset management company) and the bank, from the board member responsible for anti-money laundering (esponente responsabile per l’antiriciclaggio) to the anti-money laundering function; in a public body, whoever leads the sales.
The questions of those who check
Each unit sold is a sale of its own, with its own checks
When a portfolio is sold unit by unit, each unit has its own buyer, its own price and its own payments.
Who is buying, and with what money?
The checks look at who is buying, at the beneficial owner if the buyer is a company and, depending on the risk, at the source of the funds. In Italy they are carried out by the notary at the deed, for all parties, and by the estate agent for their own client.
Italy’s anti-money laundering law (Legislative Decree No 231/2007): customer due diligence obligations, with a risk-based approach.At which step was it checked?
A deal moves from offer to preliminary contract and on to notarial deed. Whoever answers for the checks needs to reconstruct what was checked, at which step and by whom.
Legislative Decree No 231/2007: record-keeping obligations for documents and information.Is the price the approved one?
An offer below the approved price list (listino) is either a discount that only the seller can grant or a warning sign to look into: it is not the broker’s decision. Whoever sells a portfolio wants to see it before accepting it.
How you document it with EASYRE®
In EASYRE®, the checks sit inside the deal
Each deal follows an event-based workflow, from first contact to the signing of the deed: the checks appear at the step where they are needed.
Offer (proposta)
Brokers and estate agents record the offer in EASYRE®, including offers for bare ownership, usufruct, rent-to-buy or lease.
Price check and anti-money laundering
Offers to be checked wait in the seller’s price review queue before acceptance; the anti-money laundering check on the offer is there to be signed off.
Preliminary contract (compromesso)
At the preliminary contract comes the second anti-money laundering check to sign off, and the preliminary contract price sits next to the unit’s approved price list.
Notarial deed (rogito)
At the notarial deed comes the third check to sign off, then the deed is recorded as signed. Each step is an event in the deal, and the events-by-user report shows who recorded what.
Access and documents
Access, events and documents for every sale
In a sale through multiple brokers and estate agents, the fund, the brokers and estate agents, the call centre and the credit intermediaries work together: in EASYRE® each of them enters with their own role.
Role-based access
Users are in groups: fund, manager, brokers and estate agents, call centre, credit intermediaries, anti-money laundering. Each profile sees only the data it is authorised to see.
Access and events logged, user by user
The access report shows who signed in and when; the events-by-user report shows the steps each user recorded.
The documents of each sale, with their unit
In EASYRE® documents are linked to fund, agency, building and unit, with a label saying what they are, such as the buyer’s or tenant’s privacy notice.
Frequently asked questions
Questions on checks in a property sale in Italy
How does EASYRE® help with anti-money laundering checks when a property is sold in Italy?
It brings the checks inside the deal. In EASYRE® the anti-money laundering checks to sign off appear at offer, preliminary contract and notarial deed, offers to be checked wait in the price review queue before acceptance, and the anti-money laundering function has its own user group. The checks remain with those who must carry them out by law: in Italy the notary checks all parties at the deed, the estate agent checks their own client, and, for the properties of a fund, the SGR is not required to carry out customer due diligence on the buyer (Bank of Italy provisions on customer due diligence, Part Two, Section II, footnote 10). Who does what, step by step, is in the guide AML in Italy: who does what.
How are the anti-money laundering checks on a sale documented?
With the documents collected and a record of who checked what, at which step and when. In EASYRE® each check is a step of the deal, to be signed off; the events-by-user report shows who recorded what, and the documents stay with the unit they refer to. Record keeping as required by law remains with the obliged entities, under their own procedures.
Who checks offers against the approved price list?
The seller. In EASYRE® offers to be checked wait in the price review queue before acceptance, and for each unit the approved price list sits next to the offer, preliminary contract and deed prices. When a deal closes without a sale, the reasons for closing include ‘inadequate offer’ and ‘inconsistent with the approved price list’. The price review queue is the seller’s own internal check: it is not the fairness opinion (giudizio di congruità) that the SGR asks the independent expert (esperto indipendente) to give for each property it intends to sell.
Does EASYRE® replace the SGR’s anti-money laundering procedures?
No: procedures and decisions remain with the SGR and its anti-money laundering function. EASYRE® brings them into the sale: the anti-money laundering function has its own user group, and the checks to sign off appear at offer, preliminary contract and notarial deed and stay in the history of the deal.
Does the workflow also cover bare ownership, usufruct, rent-to-buy and lease?
Yes: in EASYRE® an offer can also be for bare ownership, usufruct, rent-to-buy or lease, within the same event-based workflow of the deal.
Who sees the documents of buyers and tenants?
Those whose role allows it. In EASYRE® users are in groups and each profile sees only the data it is authorised to see; documents carry a label saying what they are, such as the buyer’s or tenant’s privacy notice, and the access report shows who signed in and when.
General information as at 30 September 2026; it is not legal advice.
For those who sell: Fund managers & large owners, Public bodies & pension funds, Banks & credit servicers, Real estate services firms.
AML, approved price list, security
Rules, prices and data, for those who answer for the checks
AML in Italy: who does what
Who checks the buyer, and at which step
The guide to the rules, roles and dates, up to 2027.
Go to the AML guide ›Approved price list
Every offer next to the approved price list
For those who answer for prices to the board of directors.
Go to Approved price list ›Security and governance
Who enters EASYRE® and what they do is on record
For those who assess ICT providers: risk, IT, data protection.
Go to Security & governance ›