Since January 2023, Germany has taken a serious approach to the shadow real estate market and banned the purchase of any property with cash or cryptocurrency. In 2025, the fight against illegal capital remains a priority for the European Union, and Germany, as one of the leading economies in the region, sets the tone in this process by introducing new restrictions.

What has changed during this time? How have buyers and sellers adapted to the new reality and what lessons can be learned from Germany’s experience? In our article, we will examine the current state of the law, its practical application and the consequences for the real estate market.

Which Methods of Payment for Real Estate are Not Allowed in Germany in 2025?

Restrictions on payment methods for real estate purchases in Germany are still in force. They are regulated by the Anti-Money Laundering Act (Geldwäschegesetz, GwG) (section 16a). 

It prohibits the use of the following assets:

  • Cash. The legality of cash is difficult to verify, and the results may not be reliable, so transactions must be digital.
  • Cryptocurrencies. Bitcoin, Ethereum, and other digital currencies, including non-fungible tokens (NFTs), cannot be used to pay for real estate. This applies to both direct purchases and transactions through companies.
  • Precious metals and stones. Gold, platinum, and precious stones are also excluded from the list of acceptable means of payment.

The ban applies to all types of real estate in the country, from residential buildings and apartments to commercial properties and land. German authorities do not plan to ease these restrictions; in fact, they are going to tighten control over compliance with the law against the backdrop of the growing popularity of cryptocurrencies in the EU.

The following are allowed to buy real estate in Germany:

  • Bank transfers. The main and most common method of payment. Buyers and sellers are required to provide the notary with confirmation of the transaction from the credit institution, such as a statement or payment order.
  • Electronic money. Payments through systems such as PayPal or other services that fall under the definition of electronic money in accordance with EU law remain permissible. This also includes stablecoins (such as USDT or USDC), if they are recognized as electronic money and are pegged to a fiat currency with clear regulation.
  • Securities. The use of traditional securities, including electronic ones registered in registries based on distributed ledger technology (DLT), is not subject to the ban. However, security tokens that do not meet the strict criteria of “securities” under German law remain prohibited.

Sunset on the famous TV tower in Berlin, Germany

How does the Control Work?

Notaries are primarily responsible for enforcing the ban. In Germany, no real estate transaction can be completed without their certification. They are responsible for checking the method of payment for the purchase and ensuring that the funds were received through permitted channels, such as bank transfer or electronic money. Only then can they submit an application to the land registry (Grundbuchamt) to re-register the property rights.

In turn, the buyer and seller must provide the notary with evidence of the legality of the transaction through bank statements, payment confirmations from credit institutions or data on the transfer via electronic money systems.

If the notary has suspicions about the legality of the origin of the funds, they can request additional information from the parties or immediately forward the information to anti-money laundering authorities, such as the Financial Intelligence Unit (FIU).

Violation Consequences

Violation of the ban does not entail administrative or criminal punishment — the transaction is simply not recognized as valid. The notary will not approve the documents and will not submit an application to the land registry, and without this, the ownership right does not pass to the buyer. Serious consequences are possible in cases where the notary or bank applies to the FIU. The latter, in turn, will begin a close inspection of the person’s finances and can bring the process to a criminal case and seizure of assets.

And How is This the Case in Other Countries?

The ban on buying real estate with cash and cryptocurrency in Germany is not an isolated initiative, but part of a broader international trend towards tightening control over financial flows and the real estate market. It began to form in the early 2010s, but the main impetus was the disclosure of the Panama Papers in 2016. The investigation showed that elites around the world use offshore accounts and real estate to launder money and evade taxes.

The fight has become especially active since 2020 due to the growth of cryptocurrency transactions. They have become a popular tool for illegal transactions, since the origin of the funds for which they were purchased is almost impossible to trace. Thus, any dubious and unreliable persons could buy real estate in EU countries.

The COVID-19 pandemic also played a role due to the sharp increase in digital transactions. This revealed the general vulnerability of digital asset control and their weak regulation in general. Then the Financial Action Task Force on Money Laundering (FATF) updated its recommendations and called on countries to strengthen monitoring of cryptocurrency and real estate transactions.

The European Union has actively joined this process. Back in 2020, the 5th Anti-Money Laundering (AML) Directive came into force, obliging countries to improve the tracking of the origin of funds. And in July 2021, the European Commission proposed a new package of measures: the creation of a specialized Anti-Money Laundering Office (AMLA), setting a limit on cash transactions of €10,000 and limiting the number of cryptocurrency transactions.

France has also strengthened its control measures, setting an upper limit for cash transactions of €1,000 for residents and €10,000 for non-residents since 2015. Italy has lowered the threshold for cash transactions from €3,000 to €1,000 by 2023, generally paying a lot of legal attention to luxury real estate transactions. The Netherlands is still only discussing a ban on cryptocurrency payments and has not yet made a final decision on this issue.

Outside the EU, measures are not always so strict. For example, in the US, cash transactions are not restricted in any way. Cryptocurrency transactions are also not regulated, but only because in US law it does not refer to currency, but to property, and must be converted into dollars before purchase. There are nuances only for legal entities and companies: the Corporate Transparency Act (CTA) in the US obliges them to report on beneficiaries. But this does not apply to individuals.

In Canada, from 2023, disclosure of the origin of funds for large real estate transactions is required, especially in Vancouver and Toronto. But only because the real estate markets in major cities are overheated by foreign investment, and the dubiousness of the transaction is a good reason for refusal.

The UAE, on the contrary, instead of bans, is actively legalizing digital assets. The Dubai Department of Land and Resources recognizes cryptocurrency as a payment method through blockchain platforms, but, as in the United States, requires conversion into dirhams. The process is carried out through licensed crypto exchanges or payment gateways such as Binance Pay or HAYVN Pay, due to which the legality of funds is fully consistent with local laws. In 2022, Dubai adopted the Virtual Assets Law (Law No. 4 of 2022), and created the Dubai Virtual Assets Regulatory Authority (VARA), which monitors cryptocurrency transactions.

The German model is closer to the Chinese regulatory methods. The Celestial Empire also completely prohibits the use of cryptocurrencies in any transactions, including real estate.

Summary

The ban on buying real estate with cash and cryptocurrency, introduced by Germany in 2023, is only part of the general trend of the EU to combat shadow capital and money laundering. During its implementation, transactions have become more transparent, and notaries have become a key figure in their execution.

However, this has increased the number of checks and made the already unwieldy bureaucracy in Germany even slower. Although the local real estate market has adapted, its attractiveness for foreign investors is declining, especially against the background of other countries without such bans.

The Arab model shows that it is better not to adapt the real estate market to existence without cryptocurrency, but to modernize the legislation itself to modern standards. Perhaps this is why the UAE is now attracting the bulk of investors in the cryptocurrency sector and remains the flagship of this field.