ONCDOFT registration: what real estate agencies and agents must do, and what you will be asked for as a client

On September 8, 2026, the Oficina Nacional Contra la Delincuencia Organizada y Financiamiento al Terrorismo (ONCDOFT, Venezuela's national office against organized crime and terrorist financing) issued Circular 003-2026, with the rules for signing up in the Registro Unificado de Sujetos Obligados (RUSO, the unified registry of regulated entities). Real estate agencies are among those required to register.

The circular replaced another one, 002-2026, issued just a week earlier, on September 1. Between the two, something important changed for the industry: who has to register. Here we explain what the current rule says, what changed, what is still unclear, and what you will be asked for as a client when you buy or sell a property.

What the RUSO is and why it exists

The RUSO is a registry of people and companies that, because of their line of work, can be used to launder money or finance terrorism. It is not new: the 2026 circulars are based on Providencia Administrativa (Administrative Order) ONCDOFT-002-2021, reprinted in the Gaceta Oficial (Official Gazette) No. 42,118 of May 3, 2021, although the RUSO page on the ONCDOFT website still cites the earlier one, 001-2021. What is new is that the ONCDOFT is now requiring, with specific requirements, the registration of sectors that in practice had not registered.

The legal basis is the Ley Orgánica Contra la Delincuencia Organizada y Financiamiento al Terrorismo (Organic Law Against Organized Crime and Terrorist Financing, Gaceta Oficial No. 39,912, 2012). Its Article 9 includes among regulated entities those engaged in buying and selling real estate (item 10) and independent lawyers, administrators, economists, and accountants when they carry out property purchases and sales and other transactions for their clients (item 9).

The context: since June 2024, Venezuela has been on the "gray list" of the Grupo de Acción Financiera Internacional (GAFI, known in English as the FATF, the Financial Action Task Force), the body that evaluates countries on anti-money laundering. Getting off that list requires, among other things, supervising non-financial sectors such as real estate. On September 2, the ONCDOFT and the UNIF (Unidad Nacional de Inteligencia Financiera, Venezuela's financial intelligence unit) presented their progress to the FATF's Joint Group for the Americas, in Tortola.

What changed between Circular 002 and 003

	Circular 002-2026 (September 1)	Circular 003-2026 (September 8, current)
Real estate sector	Real estate agents and agencies, "when they are involved in handling funds for the purchase and sale of real estate"	Only real estate agencies, with the same condition
Professionals with individual registration requirements	Lawyers, administrators, economists, and accountants	Only lawyers and accountants
Credential for individuals	Professional association or "real estate agents' chamber"	Only an institute or professional association

Circular 003 does not explain why it replaced 002. According to Cuentas Claras Digital, Circular 002 drew objections from lawyers: the Junta Interventora (court-appointed interim board) of the Bar Association of Bolívar state asked for it to be suspended and warned that it could turn lawyers into potential informants for government agencies. Circular 003 kept lawyers among the regulated entities.

Who has to register?

Real estate agencies (according to the Cámara Inmobiliaria de Venezuela, this includes offices and franchises), when they are involved in handling funds for the purchase and sale of real estate. The circular does not define what "handling funds" means. According to the Cámara Inmobiliaria de Venezuela (the Venezuelan Real Estate Chamber), the office registers and also provides information on the agents who work there.

Independent agents: this is the biggest question. Circular 003 removed "real estate agents" from the list and removed the real estate chamber credential as a requirement for individuals. It also only sets out individual registration requirements for lawyers and accountants, and the Cámara Inmobiliaria de Venezuela reported that agents who work independently do not currently have an individual registration option in the system.

But there are three caveats:

Circular 003 itself, further on in its text, still mentions "real estate agents considered regulated entities." The document is not fully consistent.

The ONCDOFT itself, in its September 11 statement, describes Circular 003 as addressed to "Lawyers, Accountants and Real Estate Agents."

The Law did not change. Article 9 still includes those engaged in buying and selling real estate. The fact that there is no registration path today does not mean that the Law's obligations, such as identifying the client, have disappeared.

If you are an independent agent, the prudent course is to start applying due diligence with your clients now and to watch for an individual registration path to open.

How registration works

The process is online: it is done in the RUSO system, which you reach from the RUSO page on the ONCDOFT website. According to the Cámara Inmobiliaria de Venezuela, the system does not complete the registration until all the data is uploaded, and it may be down for maintenance on weekends. If it does not load, try again Monday to Friday.

For a company, Circular 003 requires:

Articles of incorporation registered with the Registro Mercantil (Commercial Registry), with their amendments.

Cédula (national ID card) of the legal representatives and board members.

RIF (tax ID) of the shareholders and board members.

Notarized power of attorney for the legal representative.

If the company has a compliance officer: their cédula, their RIF, and proof of their appointment.

According to the circular, regulated lawyers, accountants, and "real estate agents," as well as NGOs and nonprofit organizations, sign an online sworn statement when they register, committing to carry out due diligence on their clients and to determine the source and destination of their funds.

Afterward:

If there are errors or missing documents, the ONCDOFT sends a notice and the registrant has 10 business days to correct them.

If everything is in order, a registration certificate is issued with indefinite validity. The circular prohibits requiring annual renewals as long as the essential registration data does not change.

Any change (address, shareholders, board of directors, representatives) must be updated within the following 30 calendar days. Failing to update can lead to suspension of the registration.

The ONCDOFT also offers in-person service at its offices for those who have trouble with the online process.

Is there a deadline? What happens if I do not register?

Neither circular sets a deadline to register, and neither the Law, nor Providencia 002-2021, nor Circular 003 establishes a specific penalty for not doing so.

That does not mean there is no risk. What the Law does penalize is failing to meet the substantive obligations, with fines in U.T. (unidades tributarias, tax units):

Obligation	Article	Fine
Keep records for 5 years	10	300 to 500 U.T.
Identify the client	11	500 to 1,000 U.T.
Report suspicious activity	13	500 to 1,000 U.T.
Do not alert the client to a report	14	1,000 to 3,000 U.T.
Identify the ultimate beneficial owner	16	1,000 to 3,000 U.T.

And on the criminal side, the Law punishes with 3 to 6 years in prison directors or employees of a regulated entity who, through negligence, contribute to money laundering.

On timing: the supervision plan published by the ONCDOFT in May provides for awareness and training campaigns in the second and third quarters of 2026. For the fourth quarter, it provides for on-site inspections of high-risk sectors and remote supervision of moderate- and low-risk sectors. The real estate sector was rated "moderate" risk, although the plan's own table of focus areas includes it, together with lawyers, among the priorities for on-site monitoring.

The Real Estate Chamber's guides

The Cámara Inmobiliaria de Venezuela published two documents for the industry:

Guía de Debida Diligencia del Cliente para Agentes Inmobiliarios (Client Due Diligence Guide for Real Estate Agents)

Guía de Evaluación Basada en Riesgo para Agentes Inmobiliarios (Risk-Based Assessment Guide for Real Estate Agents)

They are not law. They are the Chamber's own rules. The due diligence guide declares itself mandatory for agents affiliated with the Chamber and its state chambers, with internal sanctions ranging from a reprimand to expulsion. The risk assessment guide presents itself as a reference framework with recommendations.

Even so, they are the most concrete reference available on how to comply, and what they require goes beyond sales: the due diligence guide also covers rentals, property management, and appraisals.

What you will be asked for as a client

If you buy or sell through a real estate agency that applies these guides, expect to be asked for the following before you sign any document:

Always: cédula or passport, and RIF.

In most purchases and sales: a color copy of your cédula, an updated RIF, a proof of employment letter or an income certification signed by a public accountant, and a sworn statement of the source and destination of the funds.

If you buy through a company: articles of incorporation, RIF, the representative's cédula, and the identity of partners with a 25% or greater stake.

If you pay in cash or with cryptocurrency: bank statements or the wallet's transaction history.

Higher-risk cases, such as politically exposed persons, nonresident foreigners, large cash payments, or luxury properties, require enhanced due diligence.

And one important point: according to the Chamber's guide, if the client cannot be fully identified or refuses to disclose the source of the funds, the agent must refrain from starting the transaction or suspend it. An agency that asks you for these documents is not being distrustful: the Law requires it to identify its clients and the ultimate beneficial owner, and the specific list of documents comes from the industry guides.

What is still unknown

Whether the RUSO system will open individual registration for independent agents, and when.

Why the ONCDOFT replaced Circular 002 within a week. Circular 003 does not explain it.

Which authority would impose fines on real estate agencies, and at what value of the tax unit.

Whether Circular 003 will be published in the Gaceta Oficial.

When, specifically, the inspections planned for the fourth quarter will begin.

When there are answers, we will update this article.

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Sources: Circular ONCDOFT-DGCJ 003-2026 (September 8, 2026); Circular 002-2026 (September 1, 2026); Ley Orgánica Contra la Delincuencia Organizada y Financiamiento al Terrorismo (Gaceta Oficial No. 39,912), Articles 9, 10, 11, 13, 14, 16, and 36; Providencia Administrativa 002-2021 (Gaceta Oficial No. 42,118); ONCDOFT sector assessment and supervision plan (May 2026); ONCDOFT (September 11, 2026); Cámara Inmobiliaria de Venezuela (September 12, 2026) and its Instagram post; FATF statement on jurisdictions under increased monitoring (June 28, 2024); Cuentas Claras Digital (September 15, 2026); ONCDOFT on the FATF meeting.

This article is for information only and does not constitute legal advice. If your agency handles client funds, consult a lawyer about your specific obligations.