Estate agency shredded its board minutes; settlement and AML failings found

Finanstilsynet's inspection of Drammen estate agency Dialog Eiendomsmegling AS found deficiencies spanning board governance, settlement handling, buyer protection on new builds, and anti-money-laundering complianceFinanstilsynet. The supervision covered the firm's risk assessments and procedures under the Estate Agency Act (eiendomsmeglingsloven) and the Anti-Money Laundering Act (hvitvaskingsloven), compliance in engagement execution and internal control, and the handling of client funds. It builds on Finanstilsynet's preliminary report of 4 June 2026, the board's comments of 21 August 2026, and documents submitted in late September 2026.

The sharpest governance finding is that the firm has no board minutes at allFinanstilsynet: they were accidentally sent for shredding when the firm moved officesFinanstilsynet. The board must ensure brokerage procedures are drawn up and confirm that in writing (section 3-3 of the Estate Agency Act), and deliberations must be minuted and kept for the life of the company (section 6-29 of the Companies Act). Without contemporaneous minutes there is no documentation that the board discharged its duties over the last three and a half years — a situation Finanstilsynet views seriously. Substitute material shows the board did consider the procedures, but not when, how, or with what comments.

The risk assessment itself has gaps: it never assessed the risk of incorrect or misleading information from the broker outside the sales particulars (viewings, contact with prospects)Finanstilsynet, and its treatment of bid-journal risk does not cover bids never received or never passed onFinanstilsynet. Procedures for supervising trainee brokers are almost absentFinanstilsynet — no per-engagement follow-up, no control in central phases, no documented control — and monitoring is unsoundFinanstilsynet: the managing director, who assists on project engagements, monitors the compliance function's own controls instead of a monitor outside day-to-day operationsFinanstilsynet.

On settlement, the firm breached sections 3-2 second paragraph and 6-10 third paragraph in one project engagementFinanstilsynet: it transferred a purchase sum received in one transaction to cover commission and disbursements in ten other transactions in the same projectFinanstilsynet before the buyer had obtained legal protection (rettsvern) for the acquisitionFinanstilsynet — exposing the buyer to loss. Section 6-10 third paragraph requires the buyer to have legal protection before the sum is disposed of on the seller's behalf. Finanstilsynet views the error seriously but notes the breach predates the fining power in section 8-9 first paragraphFinanstilsynet, in force 1 July 2025Finanstilsynet: had it occurred after that date, a fine would have been considered.

On new-build buyer protection, the firm failed its duty of care toward buyers (section 6-3 second paragraph)Finanstilsynet in thirteen engagementsFinanstilsynet across two 2022–2024 projectsFinanstilsynet: the developer's section 12 guarantee under the Housing Construction Act — due promptly after contracting — was furnished one to ten months lateFinanstilsynet, and the firm never informed the buyers of the default or its consequencesFinanstilsynet, including that no part of the price falls due before the guarantee is in place.

On AML, the risk assessment omitted PST's threat assessment as a stated sourceFinanstilsynet, and the procedures lack a documentation duty for pre-simplified-due-diligence assessments, an adequate training plan, and internal-control coverage of reporting-duty compliance and all high-risk engagements. Screening routines do not state that beneficial owners and account holders in legal persons must be screened.Finanstilsynet Sample checks found missing account-holder data in four cases, unverified IDs in two, late or missing PEP checks in three, late or missing beneficial-owner data in two, and missing risk classifications and purpose documentation in several.

Legal basis: eiendomsmeglingsloven §§ 3-3, 6-3 andre ledd, 6-10 tredje ledd and 8-9 første ledd; hvitvaskingsloven §§ 7, 8, 9, 12, 13 and 18; boligoppføringsloven § 12.