Boutique Agency
18 October 2026
When someone wants to buy a property in France, they are often asked questions about their financial situation during their very first conversations with an estate agent. What is your profession? How have you built up your wealth? How will the purchase be financed? And can you demonstrate where the money comes from? International buyers in particular are sometimes surprised by these questions. They have sufficient funds and expect that this settles the financial side of the purchase. Especially when buying without a mortgage, it is not always clear why an estate agent wants insight into their assets and bank accounts. Nevertheless, these customer due diligence checks are a legal obligation. Every estate agent in France is required to carry out these checks. This applies regardless of the buyer’s nationality, the purchase price or the way in which the purchase is financed.
These obligations form part of the European regulations aimed at combating money laundering and terrorist financing. In France, they are laid down in the Code monétaire et financier and are referred to as the LCB-FT regulations (lutte contre le blanchiment de capitaux et le financement du terrorisme).
A legal obligation for all French estate agents
Property transactions are vulnerable to money laundering risks because of the substantial amounts involved and the various ways in which a purchase can be financed. Estate agents, notaries and banks must therefore identify their clients, assess the background of transactions and investigate whether the funds being used have an explainable origin. For estate agents, this obligation has existed in France since 1998. The regulations have been tightened several times since then. The French supervisory authority DGCCRF and the financial intelligence unit Tracfin published joint guidelines for property professionals in November 2018. Practical information brochures were added in February 2026.
Customer due diligence must take place before a business relationship is established. This means that the estate agent must establish the identity of their client and collect relevant information about the purpose and nature of the relationship before a mandat is signed. The obligations also arise at an early stage when assisting buyers. According to the DGCCRF and Tracfin guidelines, the identification procedure must begin as soon as interest in a property becomes concrete, for example when making an offer. The identification obligations must be fulfilled when handling that offer and before an avant-contrat, such as a compromis de vente or promesse de vente, is drawn up. The checks therefore cannot be postponed until the notary prepares the final transfer of ownership. Failure to comply with these obligations can have serious consequences for an estate agency. The DGCCRF supervises compliance, and breaches can result in substantial penalties, including financial penalties and professional disciplinary measures.
The origin of the funds and the origin of wealth
Customer due diligence distinguishes between two concepts: origine des fonds and origine du patrimoine. The origine des fonds concerns the origin of the money used to pay for the specific purchase. This may be savings, the proceeds from the sale of a property, an inheritance, a gift or a loan. The origine du patrimoine goes a step further and concerns how someone has built up their wealth. For example, through employment income, business activities, investments, an inheritance or the sale of a property or business. This distinction is important. A bank statement showing €800,000 demonstrates that the buyer has that amount available. However, it does not explain how the money was obtained.
When the amount comes from the sale of a property, the notarised deed of sale, together with the financial settlement statement and proof of receipt of the sale proceeds, may provide sufficient clarification. In the case of an inheritance, documents relating to the estate may be required, while the sale of a business may require the purchase agreement. For international buyers, demonstrating the origine des fonds is, in practice, almost always part of the purchasing process. Many finance their French property with wealth accumulated in another country and transferred from a foreign bank account. The professionals involved must be able to establish where these funds come from and whether the financing is consistent with the buyer’s known circumstances. Even when a buyer pays the entire purchase price from their own funds, the origin of the money must be investigated. When a purchase is financed entirely through a mortgage from a regulated bank, the source of financing is generally easier for the estate agent to establish. When a buyer uses their own assets, however, it must be determined how those funds were obtained. This applies, for example, to savings, the proceeds from the sale of a property, an inheritance or the sale of a business. In the case of international money flows, it must also be assessed whether additional checks are necessary. When funds pass through multiple countries or accounts, originate from third parties or come from countries with a higher risk profile, more extensive investigations may be required.
Which documents are required?
The documents required depend on the source of financing. A valid identity document is always the starting point. In addition, information is requested about the buyer’s profession, financial background, how the purchase will be financed and, where necessary, the origin of the funds used for that purpose. In the case of savings, bank statements and information about income may be required. When the funds come from the sale of a previous property, the deed of sale and the accompanying financial settlement statement may be requested. In the case of an inheritance or gift, documents are required that demonstrate the legal background and the flow of funds. When part of the purchase price is provided by family members, it must also be clear whether this constitutes a gift or a loan and who is providing the funds. When purchasing through a société civile immobilière (SCI) or another company, the ultimate beneficial owners, the bénéficiaires effectifs, must also be identified. It must also be clear how the company is financed.
The principle is not that every buyer must provide an extensive financial file. Sufficient information must be available to assess the financing and, where necessary, the origin of the funds. No more information may be requested than is necessary for customer due diligence.
Why do the estate agent, the bank and the notary ask the same questions?
A common misconception is that investigating the origin of funds is solely the responsibility of the notary. In reality, the estate agent, the notary and the banks involved each have their own legal obligations. The estate agent must carry out customer due diligence before establishing the business relationship. The notary examines the transaction as part of their own responsibilities, while the banks monitor the money flows passing through their accounts.
As a result, a buyer may have to provide the same information several times. This is not always efficient, but it is a consequence of the separate responsibilities of the professionals involved. When the origin of the funds cannot be sufficiently established, the professionals involved may not carry out or continue the transaction under the applicable legal conditions. If money laundering is suspected, there may also be an obligation to submit a report to Tracfin. A request for additional information does not, however, mean that a buyer is suspected of unlawful conduct. It is part of the standard customer due diligence process.
How has tóco d’azur organised this?
For estate agents, these checks are not always the most pleasant part of their services. A property purchase usually begins with conversations about housing preferences, locations and properties. Asking personal questions about someone’s financial situation and how they have accumulated their wealth does not necessarily feel natural in that context. We experience this at tóco d’azur as well. We understand that buyers may consider such questions intrusive, particularly when they have already provided the information to their bank. Nevertheless, we have no choice in this matter. The law requires us to carry out these checks, and failure to comply with these obligations exposes us to serious penalties.
To make the process as careful and straightforward as possible for our clients, we use VigImmo, a specialised digital system developed by the French company Legapass. Legapass is supported by the French Ministries of Economy and Finance and the Direction générale des Entreprises, within the France Legaltech programme. The company also offers a comparable solution for notaries called VigiNot. With VigImmo, we can identify clients, carry out the relevant checks and carefully and securely record the accompanying documents. The data is processed in accordance with applicable privacy regulations and retained in the system for the legally prescribed period.
This enables us to carry out customer due diligence in a structured manner, without requesting more information or documents than necessary to comply with our legal obligations. It is important to emphasise that these obligations apply to all French estate agents. A buyer who chooses to work with another estate agency will, in principle, be subject to the same legal checks. The main difference lies in how an agency organises the process and guides its clients through it.
Transferring the purchase price to the notary: beware of fraud
When purchasing property in France, the purchase price is generally not paid directly to the seller but transferred to the notary’s client account. The notary receives the money, checks that the required amounts are available and handles the financial settlement of the transaction after the signing of the acte authentique. For this purpose, the buyer receives a payment request, the appel de fonds, containing an overview of the amounts due and the bank details of the notary’s office.
Particular caution is required at this stage. In France, too, criminals sometimes intercept or imitate email correspondence between buyers, estate agents and notaries’ offices. They then send a fraudulent payment request containing altered bank details. Because such messages often closely resemble the usual correspondence from the notary’s office, the fraud can be difficult to recognise. Always verify the notary’s bank details by telephone before transferring any money. Use a telephone number that you have previously received or independently verified, rather than a number provided only in the payment request. Be particularly alert if you receive a message shortly before completion asking you to transfer the money to a different account. A change in bank details must never be accepted solely on the basis of an email.
For an international purchase, it is also advisable to prepare the bank transfer well before the completion date. Banks may ask additional questions about the transaction or the origin of the funds, and international transfers may take longer than expected. The notary must have received the full amount due in good time for the transfer of ownership to take place.
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