AML obliged entities Belgium: 32 categories and obligations

In brief

The Belgian Act of 18 September 2017 subjects 32 categories of professionals to anti-money laundering obligations: financial institutions, notaries, lawyers, accountants, real estate agents, domiciliation centres, company service providers and others. Every obliged entity must apply KYC, report suspicions to the CTIF, retain documents for 10 years and train staff annually. Sanctions range from 50,000 to 5 million euros depending on the category.

Introduction: 32 Categories of Obliged Entities

The Law of September 18, 2017 identifies 32 categories of professionals required to comply with AML/CFT in Belgium. For every category, the first step is to produce a documented AML risk assessment and to build compliant KYC files.

Affected sectors:

🏦 Financial institutions

🏢 Real estate and legal professions

💎 Trade in valuable goods

🏛️ Domiciliation centers (Art. 5 §1, 18°)

The 32 Categories (Art. 5)

Main Groups

Financial sector:

Credit institutions, payment institutions

Investment firms

Life insurance companies

Regulated professions:

Notaries, bailiffs

Lawyers (financial transactions)

Auditors, accountants

Real estate agents

Trade:

Art dealers (> €10,000)

Precious metals and stones

Business services ⭐:

Domiciliation centers

Trust service providers

Virtual currency providers

Common Obligations

1. Identification

TypeScript

interface ObligedEntity {
  category: CategoryAML;
  obligations: {
    cdd: boolean; class="code-comment">// Always true
    edd: boolean; class="code-comment">// Risk-based
    ctifReporting: boolean; class="code-comment">// Always true
    recordKeeping: boolean; class="code-comment">// 10 years
    training: boolean; class="code-comment">// Annual
  };
}

2. CTIF Reporting (Art. 47)

All obliged entities report:

Suspicious transactions

Identification refusal

Unexplained operations

3. Record Keeping (Art. 34)

10-year retention:

Identification documents

Transaction proofs

Risk analyses

Specific: Domiciliation Centers

Article 5 §1, 18° requires additional:

✅ Verify real activity (no mailboxes)

✅ UBO identification via register

✅ Monitor structure changes

✅ Refuse high-risk domiciliations

TypeScript

async function evaluateDomiciliationRisk(
  company: CompanyData
): Promise<RiskAssessment> {
  const kboData = await companyBelgiumAPI.companies.get(
    company.enterpriseNumber
  );
  
  const redFlags = {
    noPhysicalAddress: !kboData.addresses.some(a => a.typeCode === class="code-string">'BAET'),
    complexStructure: kboData.branches.length > 10,
    highRiskNACE: [class="code-string">'64.19', class="code-string">'64.99'].includes(kboData.naceCode),
  };
  
  return {
    acceptable: Object.values(redFlags).filter(Boolean).length < 2,
  };
}

Sanctions

Category	Administrative	Criminal
Domiciliation	€50k - €5M	6mo - 5yr
Banks	€50k - €5M	6mo - 5yr
Professions	€10k - €500k	6mo - 3yr

Automate your AML compliance - 100 free verifications/month

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Related articles:

Law of September 18, 2017

UBO Register

Frequently asked questions

Which professions are subject to the anti-money laundering law in Belgium?

The Act of 18 September 2017 subjects 32 categories of professionals to AML obligations in Belgium. These include credit institutions, life insurance companies, notaries, lawyers in financial transactions, statutory auditors, accountants, tax advisors, real estate agents, art dealers above 10,000 euros, casinos, company service providers and domiciliation centres. Virtual asset providers have also been included since the transposition of the 5th Directive.

What are the common obligations for all AML obliged entities in Belgium?

All obliged entities must fulfil four fundamental obligations: apply client due diligence procedures (standard or enhanced KYC depending on risk), immediately report any suspicious transaction to the CTIF, retain all identification and transaction documents for 10 years from the end of the relationship, and train staff annually on money-laundering techniques and internal procedures. Each obliged entity must also appoint an AMLCO and produce an overall risk assessment.

What sanctions does non-compliance with AML obligations bring for an obliged entity in Belgium?

Sanctions vary by category. For domiciliation centres and large institutions, administrative fines range from 50,000 to 5 million euros. For liberal professions, from 10,000 to 500,000 euros. Criminal sanctions provide between 6 months and 5 years' imprisonment depending on severity. For repeat offences, penalties are doubled. Legal persons are also criminally liable since the transposition of 6AMLD.

Do company service providers and domiciliation centres have specific AML obligations in Belgium?

Yes, Article 5, paragraph 1, point 18 of the Act imposes additional obligations on them. They must verify the real economic activity of the domiciliated entity (no empty mailboxes), identify beneficial owners via a 3-level UBO cascade, monitor structural changes, maintain a service register and be registered with SPF Economie. Domiciliation is systematically classified as high risk, which automatically triggers enhanced due diligence measures.