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The real estate sector has been in the special focus of supervisory authorities and investigative bodies for years. With the continuous tightening of the Money Laundering Act (AMLA), extended due diligence obligations and an increasingly active role of the Financial Intelligence Unit (FIU) also in the non-financial sector, the validation of transaction prices in the real estate sector is becoming increasingly important.
While real estate valuation has traditionally been used to collateralize loans, it is increasingly becoming a key pillar of an effective anti-financial crime (AFC) strategy. The "true value" of a property is more than a key figure, it is a reference value, control instrument and early warning system at the same time.
Money laundering in the real estate sector is rarely spectacular, but systematic. It is not the object itself that is the instrument of action, but the transaction price. The manipulation of the value base makes it possible to transfer illegal funds into the legal economic cycle.
In practice, three central typologies can be distinguished:
These patterns show that the plausibility of the purchase price is not a purely market economy issue, but a compliance indicator.
Quality-assured appraisals in accordance with recognised standards such as the Real Estate Valuation Ordinance (ImmoWertV), the Mortgage Lending Value Determination Ordinance (BelWertV) or the guidelines of the Royal Institution of Chartered Surveyors (RICS) provide objective reference values. These form the basis for reliable transaction monitoring in the real estate sector.
A professional valuation performs several AFC-relevant functions:
Real estate valuation thus becomes a structured reality check of economic assumptions.
In order for the valuation to be fully effective, it must be systematically embedded in the internal control and compliance system.
A structured implementation approach includes, in particular:
The decisive factor is that the valuation must not end up as a static PDF in the loan file. It must be understood as a dynamic part of the KYC and monitoring process.
For management, management boards and supervisory boards, the integration of real estate valuation into the AFC strategy is not just a compliance issue, but an element of active risk management.
A superficial or erroneous valuation contains:
Professional assessment, on the other hand, creates transparency, traceability and documentation security – central factors in the dialogue with supervisors and audit bodies.
The "valuation gap", i.e. the difference between economic reality and the declared transaction price, is not a purely market-driven phenomenon. It is a potential indicator of financial crime.
Those who consistently integrate real estate valuation into their risk management not only strengthen their compliance structure, but also protect assets, reputation and management responsibility in equal measure.
An effective prevention strategy in the real estate sector requires interdisciplinary competence at the interface of valuation, regulation and forensics.
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