# The GwG check in a brokerage: who checked what, and when? > How a German brokerage documents its anti-money-laundering (GwG) check on the deal: identification, PEP check, source of funds, five-year retention — with screenshots. Canonical: https://capitality.io/geschichten/gwg-pruefung-makler · German version: https://capitality.io/geschichten/gwg-pruefung-makler.de.md · All stories: https://capitality.io/geschichten.md Source: generated from `apps/landing/src/app/content/stories/gwg-pruefung-makler.json` by `apps/landing/scripts/build-story-twins.mjs` — do not edit by hand. Updated: 2026-09-27. The people and brokerages in our stories are fictional; the workflows are typical of brokerages in Germany. The screenshots come from the product, captured with sample data. **Martin Scholz** (Fictional person) — Owner, Veedelwerk Immobilien, Köln. Founded Veedelwerk Immobilien in 2012; four people on the team, focused on condominiums in western Cologne. Wants to know on Monday where every deal stands — without four phone calls. Martin Scholz runs Veedelwerk Immobilien and answers for its duties under the German Anti-Money Laundering Act (GwG). The records used to be scattered across binders and inboxes. Now they sit on the deal — with a name, a date and a note for every step. ## In short - The GwG check is part of every deal: six steps from identification to filing, each with a note, a name and a date. - A deal with a GwG record cannot be deleted — it is set to “Verloren” (lost) and kept. - Pipeline value and analytics show where every deal stands, without anyone maintaining a list. ## The situation: The records live in binders, inboxes and heads — until the supervisor asks. Under the German Anti-Money Laundering Act, real estate agents are obliged entities. For every sale they must identify seller and buyer, establish beneficial owners, check whether a politically exposed person is involved, and keep the records for five years. In the end, the owner is responsible. At Veedelwerk, these records long stayed wherever they happened to be created: ID copies in a binder, the financing confirmation in an inbox, the rest in the head of the colleague handling the sale. Anyone tracing a case months later had to search — and hope nobody had deleted the old CRM entry. Martin didn't want a second file. He wanted one place where the check belongs to the deal: visible to the team, traceable for him, and protected from clean-ups. ## How it works in Capitality Five images from the sale of a condominium in Ehrenfeld: Lea Brandt handles the deal, Martin Scholz keeps the overview. ### Step 01 — The check lives in the deal Six steps, each with a hint of what counts as evidence. Whoever ticks a step appears next to it with name and date; the note says how it was checked. Add the risk rating. Capitality verifies nothing automatically — it records what your team checked. ![GwG check on a deal: five of six steps done, each marked “Lea Brandt · 27.09.2026” with a note such as “ID card presented in the original, copy in the property file”.](https://capitality.io/geschichten/gwg-pruefung-makler/01-gwg-pruefung-im-deal-large.webp) ### Step 02 — Who is buyer, who is seller? Both parties are linked to the deal with their role. That makes clear whom the team has to identify — and who stands on which side of the purchase contract. ![Lower part of the GwG check with the risk rating “Normal” and the deal's links: Klaus Wagner with the role buyer, Maria Becker with the role seller.](https://capitality.io/geschichten/gwg-pruefung-makler/02-kaeufer-und-verkaeufer-large.webp) ### Step 03 — Delete it? Not with a GwG record If someone tries to delete the deal, Capitality refuses: the records must be kept for five years (§ 8 GwG). Instead of deleting, the team sets the deal to “Verloren” (lost) — the record stays. ![Message on a delete attempt: this deal contains a GwG check and must be kept for five years (§ 8 GwG); set it to “Verloren” instead of deleting it.](https://capitality.io/geschichten/gwg-pruefung-makler/03-aufbewahren-statt-loeschen-large.webp) ### Step 04 — Monday morning: the pipeline in euros Every card is a deal with its expected commission, every column a stage — from first contact to closing. The pipeline value sits on top. ![Sales pipeline with four stages — first contact, viewing, offer, closing — each holding one deal with its expected commission; pipeline value 142,658 euros.](https://capitality.io/geschichten/gwg-pruefung-makler/04-pipeline-in-euro-large.webp) ### Step 05 — The analytics Open, won and lost deals, commission per stage, how many deals make it to the next stage — and which have not moved for more than 14 days. The pipeline value covers open and won deals. ![Pipeline analytics: three open deals, pipeline value 142,658 euros, one deal won; below, a table by stage with commission, days in stage and the rate to the next stage.](https://capitality.io/geschichten/gwg-pruefung-makler/05-pipeline-auswertung-large.webp) ## What of this is in the product today The story shows only what is in the product today. Anything next to it that is in build or planned is marked as such — with the same marks as on the brokerage page. Legend: ✓ in the product today · → in build · ○ planned - ✓ GwG checklist on the deal with proofs, risk rating and history - ✓ Deal pipeline (Kanban) with commission in EUR and pipeline value - ✓ Pipeline report: deals per stage, time in stage, stuck deals - ○ Commission invoice ## The short version for your team 1. Create deals on a sales board — for example straight from an enquiry. 2. Link buyer and seller to the deal with their roles. 3. Tick the steps of the GwG check and note for each how it was verified. 4. Set the risk rating and record where the documents are filed. 5. Set cancelled deals to “Verloren” (lost) instead of deleting them. ## Frequently asked questions **Does the Anti-Money Laundering Act apply to real estate agents?** Yes. Real estate agents are obliged entities under § 2(1) no. 14 GwG — always for purchases and sales, and for brokering rentals and leases from a monthly rent of 10,000 euros. **When must the buyer be identified?** As soon as the brokerage client expresses a serious interest in carrying out the purchase contract and the parties to it are sufficiently determined (§ 11(2) GwG). Capitality states this point in time right on the check step. **How long must GwG records be kept?** Five years (§ 8(4) GwG). That is why Capitality does not let you delete deals with a GwG record; they are set to “Verloren” (lost) and kept with their history. **Does Capitality check PEP lists or the transparency register automatically?** No. You or your team carry out the check; Capitality records who checked what and when, with your note as evidence. Every change — ticked, unticked, note edited — is in the deal's history. ## Legal basis and sources - [§ 2 GwG — Obliged entities (German)](https://www.gesetze-im-internet.de/gwg_2017/__2.html) - [§ 8 GwG — Recording and retention (German)](https://www.gesetze-im-internet.de/gwg_2017/__8.html) - [§ 10 GwG — General due diligence (German)](https://www.gesetze-im-internet.de/gwg_2017/__10.html) - [§ 11 GwG — Identification (German)](https://www.gesetze-im-internet.de/gwg_2017/__11.html) This is not legal advice. The statutory text in its current version is authoritative. ## More stories - [From contact form to deal — without retyping](https://capitality.io/geschichten/anfrage-zum-deal) — Every enquiry gets typed in three times: into the CRM, the pipeline and a note. - [Mandatory disclosures in the exposé — checked before it goes out](https://capitality.io/geschichten/expose-pflichtangaben) — One missing energy certificate detail is enough for a cease-and-desist letter. ## What story would your office tell? 30 minutes on your own stock: enquiry, deal, exposé check, GwG check — on your properties instead of our sample data. We reply the same business day. One to three design-partner seats for brokerages in the DACH region: a direct line to the product team, your order decides what gets built. Contact: the “Demo on your stock” and “Become a design partner” buttons on https://capitality.io/immobilienvertrieb open an e-mail to us (we reply the same business day).