In 2025, Ukraine has tens of thousands of active real estate transactions worth billions of hryvnias. At the same time, there is a law that requires real estate agents to identify suspicious transactions and report them to the state. And there has been just one report in eight years.
The figure that the Ministry of Finance called "sensitive"
According to Olena Haidamakha, president of the Association of Real Estate Professionals of Ukraine, the statistics were disclosed at an event where the Ministry of Finance was explaining new rules of interaction with the State Financial Monitoring Service to real estate agents.
"For the entire 2025 — only one report of a suspicious transaction. And for 2018–2024 — zero altogether."
Olena Haidamakha, president of AREPPU
In response to LIGA.net's inquiry, the Ministry of Finance neither confirmed nor refuted these figures — and explained this by saying the data is sensitive in conditions of wartime. In other words: neither "yes" nor "no," but also not "false."
The law exists. The mechanism — does not
Real estate agents became subjects of primary financial monitoring back in 2010. Law No. 361-IX, which came into force in April 2020, enshrined a risk-based approach: reporting is required not for all transactions, but only for suspicious operations or attempts to carry them out — regardless of the amount.
Formally, subjects are required to take three steps: register in the State Financial Monitoring Service system, apply the KYC ("know your customer") approach, and report suspicious transactions. The problem is that registration and reporting are different things. In 2025, the Ministry of Finance together with the State Financial Monitoring Service updated the technical interaction tool — the E-cabinet — and is checking whether all subjects have registered at all.
"The sector either doesn't know how or isn't ready"
Haidamakha does not present this statistic as a success. Rather, as a diagnosis.
"Given such market volumes, this testifies not to the absence of risks, but rather to the fact that the sector either does not yet know how or is not ready to identify them."
Olena Haidamakha, president of AREPPU
A common misconception among real estate agents is that financial monitoring only applies to transactions exceeding 400,000 hryvnias. The Ministry of Finance has repeatedly refuted this: no threshold amount is set for real estate agents, the criterion is the nature of the transaction, not its size. That is, a transaction for 200,000 hryvnias can fall under reporting if there are signs of suspicion.
What lies behind the zero
There are several explanations for why the indicator is so low — and none of them testify to a clean conscience of the market:
- Ignorance of the rules. Some real estate agents still do not understand what exactly is considered a "suspicious transaction" according to the Ministry of Finance's orders.
- Unwillingness to conflict with clients. Reporting one's own client means losing the deal and commission.
- Lack of real oversight. The mechanism of sanctions for non-compliance with SFMS obligations exists on paper, but there have been no mass inspections of real estate agents.
- An unregulated market. Ukraine still has no mandatory license for real estate agents, and AREPPU itself warns of the risk of "corrupt" regulation of the industry.
That is why in 2025 the state is moving in two directions simultaneously: technically updating the interaction system through the E-cabinet and considering regulation of the real estate services market itself — with clear rules on contracts, payment, and the liability of intermediaries.
The question is not whether there are suspicious transactions on the real estate market — there are. The question is whether a mass check of real estate agent registration in the E-cabinet will be the first step toward real sanctions for silence — or will again end with explanatory online events.
