Compliance Gates & Jurisdictions
Buyer Desk implements fail-closed compliance semantics: every brief is blocked from matching until human brokers verify jurisdiction-specific gates. This section documents each gate and its verification process.
Fail-Closed Architecture
By default, all gates block. Matching proceeds only after broker verification.
Brief created
↓
Gates seeded as pending (per jurisdiction)
↓
Guardian (compliance engine) checks: gate verified?
↓
Gate verified? → proceed
↓
Gate pending or failed? → BLOCK (brief status: blocked_compliance)
↓
Broker verifies gate in dashboard
↓
Brief resets to active, matching re-triggersThis is intentional. A brief with unverified gates cannot match candidates. Compliance is never assumed; it is explicitly verified and recorded by the broker.
Latin America: AML/KYC Gate
Onoots treats Latin America as a region with a shared regulatory profile: dual currency (local + USD for high-value transactions), emerging buyer representation, and a single AML/KYC gate. Country packs (Mexico, Colombia, Argentina, and others) inherit the same model.
aml_kyc — Anti-Money-Laundering (regional FIU)
| Property | Value |
|---|---|
| Jurisdiction | LATAM (region; per-country pack) |
| Regulatory Authority | The country’s Financial Intelligence Unit (UIF Argentina, UIAF Colombia, UIF Mexico, etc.) |
| Requirement | Know-Your-Customer due diligence; buyer identity and source-of-funds verification |
| Applies to | All transactions; reinforced above country cash thresholds |
| Verified by | Brokerage compliance officer or broker |
| Evidence | ID/passport, proof of address, bank statements for high-value transactions |
In most Latin American countries, real-estate intermediaries are “obligated subjects” (reporting entities). The reporting threshold and retention period vary by country (commonly 5 years). Onoots does not store sensitive buyer documents; brokers keep independent compliance files.
Canada Ontario: Three Gates
1. foreign_buyer — Foreign Buyer Status
| Property | Value |
|---|---|
| Jurisdiction | CA-ON (Canada Ontario) |
| Requirement | Determine whether the buyer is a Canadian resident or a foreign national |
| Why | Foreign buyers can trigger additional taxes (speculation tax) |
| Verified by | Agent during intake (self-reported) + broker confirmation |
| Evidence | ID + proof of residency (lease, utility bill, tax return) |
2. fintrac — FINTRAC Compliance
| Property | Value |
|---|---|
| Jurisdiction | CA-ON (Canada Ontario) |
| Regulatory Authority | FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) |
| Requirement | Large Cash Transaction report (≥ CAD 10,000); Suspicious Activity Report (SAR) |
| Applies to | Transactions with cash down payment ≥ CAD 10,000 |
| Verified by | Brokerage lawyer or compliance officer |
| Evidence | Bank statements, proof of funds, source-of-funds declaration |
FINTRAC is linked to the RCMP. Failure to report Large Cash Transactions is a federal offense. If a brief’s availableCash ≥ CAD 10,000, the fintrac gate must be verified before any matching occurs.
3. bra — Buyer Representation Agreement (BRA)
| Property | Value |
|---|---|
| Jurisdiction | CA-ON (Canada Ontario) |
| Regulation | Real Estate Services Act (RESA); Trades Act (Ontario) |
| Requirement | Signed BRA between brokerage and buyer before showing properties |
| Why | Establishes agency relationship, commission right, fiduciary duty |
| Verified by | Brokerage with signed document |
| Evidence | Scanned signed BRA (TREB-approved form or equivalent) |
United States: Four Gates
The largest and most mature market. After the NAR settlement (2024), a written buyer-representation agreement is required before showing properties across much of the country.
1. state_license — State License
| Property | Value |
|---|---|
| Jurisdiction | US (per-state pack) |
| Requirement | The agent must hold an active real-estate license in the transaction’s state |
| Why | Licensing is state-level, not federal; operating unlicensed is an offense |
| Verified by | Brokerage (verifies the agent’s active license) |
2. buyer_agency — Buyer Representation Agreement
| Property | Value |
|---|---|
| Requirement | Signed buyer–broker agreement before showing properties (post-NAR settlement, 2024) |
| Why | Establishes agency and the buyer broker’s compensation |
| Evidence | Signed agreement (state/local MLS-approved form) |
3. fincen_aml — FinCEN AML Reporting
| Property | Value |
|---|---|
| Regulatory Authority | FinCEN (Financial Crimes Enforcement Network) |
| Requirement | Residential Real Estate Rule: beneficial-ownership reporting on non-financed transfers to legal entities/trusts |
| Verified by | Settlement professional / compliance officer |
| Evidence | Beneficial ownership, source of funds |
4. firpta — FIRPTA Withholding (foreign seller)
| Property | Value |
|---|---|
| Requirement | Tax withholding (typ. 15%) when the seller is a foreign person |
| Applies to | Applies on the sell side; the gate flags the transaction for the closing agent |
US licensing is state-level and taxation varies by state/county. Buyer Desk flags the gates; the brokerage confirms licenses and closing procedures locally.
United Arab Emirates (UAE): Three Gates
A strong foreign-investment market (Dubai, Abu Dhabi). Currency AED (pegged to USD). No income tax or capital-gains tax; the main cost is the DLD transfer fee.
1. rera_registration — RERA/DLD Registration
| Property | Value |
|---|---|
| Regulatory Authority | RERA (Real Estate Regulatory Agency) / DLD (Dubai Land Department) |
| Requirement | Broker and transaction registered with RERA/DLD |
| Evidence | RERA broker card; transaction registered with the DLD |
2. freehold_eligibility — Foreign Ownership Eligibility
| Property | Value |
|---|---|
| Requirement | Foreign ownership is allowed only in designated freehold zones |
| Why | Outside freehold zones, foreigners cannot hold full title |
| Verified by | Broker (confirms the unit is in a freehold zone) |
3. uae_aml — AML (goAML / FIU)
| Property | Value |
|---|---|
| Regulation | Federal Decree-Law No. 20 (2018); real estate as a DNFBP |
| Requirement | KYC + suspicious-transaction reporting to the FIU via goAML |
| Evidence | Identity, beneficial ownership, source of funds |
Property ≥ AED 2M can qualify the buyer for the Golden Visa — a strong commercial hook, but not a compliance gate.
Gate States & Transitions
pending → verified (broker confirms compliance)
→ failed (broker flags non-compliance)
blocked_compliance (at least one gate pending/failed)
↓
[broker verifies all gates]
↓
active (brief ready to match)Verification Audit Trail
Every gate verification is recorded:
{
"brief_id": "brief_abc123",
"type": "aml_kyc",
"status": "verified",
"human_approver": "Broker (broker_id: bro_xyz)",
"verified_at": "2026-07-04T14:32:00Z",
"jurisdiction": "LATAM"
}This audit trail is:
- Broker-accessible in the dashboard (read-only)
- Not exposed to agents (compliance is a broker-only view)
- Immutable — verified gates cannot be un-verified; open a support ticket if an error occurs
Gate Matrix by Jurisdiction
| Jurisdiction | Gates |
|---|---|
| Latin America | aml_kyc |
| Canada (Ontario) | foreign_buyer · fintrac · bra |
| United States | state_license · buyer_agency · fincen_aml · firpta |
| UAE | rera_registration · freehold_eligibility · uae_aml |
Each brief is bound to a single jurisdiction. Brokers manage gates per-brief; switching jurisdiction requires creating a new brief.
Onoots does not provide legal advice. Brokers are responsible for maintaining independent compliance with all local and federal regulations. Use Buyer Desk as a workflow tool, not a substitute for legal advice.
API: Verify Gate
PATCH /api/dashboard/buyer/briefs/brief_abc123/compliance
Authorization: Bearer <broker-jwt>
Content-Type: application/json
{
"type": "aml_kyc",
"status": "verified"
}Response:
{
"ok": true,
"allVerified": false, /* at least one gate still pending */
"retriggered": false /* not all gates verified, no re-trigger */
}If all gates verified:
{
"ok": true,
"allVerified": true,
"retriggered": true /* brief resets to active, matching re-triggers */
}Errors:
| Status | Error | Cause |
|---|---|---|
| 403 | forbidden | Caller is not a broker; must have broker role |
| 404 | not_found | Brief or gate does not exist |
| 409 | already_verified | Gate was already verified; cannot re-verify |
Next: Market Validation
Learn about the launch markets: regulatory landscape, financing, and market conditions across Latin America, Canada (Ontario), the United States, and the UAE.