Tilsynsrapport - Dialog Eiendomsmegling AS

The firm's risk assessments and procedures under the Real Estate Agency Act and Anti-Money Laundering (AML) Act were found deficient. Notably, the absence of board minutes means the board cannot demonstrate it fulfilled its statutory duties—a governance red flag. In one settlement, client funds were disbursed before the seller's legal protection was secured, breaching client money rules.

In several assignments, the firm failed its duty of care to buyers regarding the seller's guarantee obligation under the Housing Construction Act §12. AML compliance in assignment execution also had weaknesses. For compliance teams, this underscores the need to: (1) review and strengthen risk assessments and procedures for real estate agency and AML compliance; (2) ensure board meetings are properly minuted and governance duties documented; (3) implement robust controls over client fund flows, ensuring disbursements only occur after seller's legal protection; (4) verify seller guarantee obligations under housing construction law; and (5) enhance AML monitoring in transaction execution.

Firms should treat this as a warning: regulators are focusing on governance, client money, and AML in real estate intermediation. Proactive remediation can prevent enforcement action and reputational damage. Consider leveraging RegTech solutions for AML and client fund management.

This report also signals increased scrutiny across the real estate sector, with potential for broader thematic reviews.