Development is not the same as brokerage — but every sale still needs a clean KYC, cash and evidence hand-off.

Why it matters

Own-stock sales, off-plan projects and build-to-demand deals often sit beside AML touchpoints without making the developer an estate-agent obliged entity by default.

Where the scope gets real

For developers, the honest boundary matters. Selling your own stock is generally evidence/support mode; registered estate-agent activity, third-party brokerage, a separate intermediation arm or suspicion can bring a file into AMLR real-estate scope.

Where teams lose time

That still leaves real operational work: banks and notaries ask for structured client facts, sanctions comfort, payment explanations, source-of-funds evidence and a record that cash or unusual payment structures were handled properly.

Typical files and mandate types

• Off-plan apartment sales where the notary or bank asks for clear buyer evidence
• Mixed groups with a development company and a separate estate-agent or sales brokerage arm
• Deals where a buyer, payment route or cash expectation creates suspicion even if the project is own stock

What Sceau does

• Developer support mode for own-stock and off-plan projects
• Full real-estate gate when brokerage or suspicion applies
• Notary/bank KYC hand-off evidence without pretending Sceau replaces legal judgment

What usually goes wrong

• Marketing own-stock sales as if they were always AMLR estate-agent files
• Missing evidence when the notary or bank asks why a buyer was accepted
• A brokerage or intermediation arm being treated like ordinary development

How Sceau works in practice

• Classify the deal as own-stock support mode, registered-agent activity, third-party brokerage or suspicion override
• Store buyer evidence, sanctions screening, cash-control notes and notary/bank hand-off evidence in one file
• Escalate to the full real-estate CDD gate when intermediation or suspicion makes that appropriate

What changes operationally

• Developers avoid overclaiming legal status while still keeping a defensible evidence trail
• Brokerage files are not lost inside ordinary project sales
• The notary, bank and internal team see the same clean record

What stays under your control

Sceau keeps developer files in the right lane. Own-stock files become notary/bank KYC hand-off records; brokerage or suspicious files move into the full real-estate gate with both sides, accepted-offer timing and transfer evidence.