Strengthening compliance through practical risk management
On 8 July 2026, HMRC published updated guidance for the businesses it supervises regarding their Money Laundering obligations. Estate agents should already be registered with HMRC for money-laundering purposes and have robust policies and procedures in this regard, because failure to comply with money-laundering rules carries significant penalties.
In light of the latest guidance, we have put together the following top tips for estate agents wanting to ensure best practice in this area:
Know your risk
Not all property transactions are equal for money laundering risk. And a sale which is run of the mill for your firm could be high risk for the agents down the road because it’s not their core business – and vice versa. Good AML policies start by knowing, and documenting, your risk. What does your typical customer look like? What properties are you instructed on? Would you expect to act for politicians? Do you act for corporations on selling portfolios of properties. Set it all down and direct your resources to the areas where you’re most exposed to risk.
Know your client
The acronym CDD, or customer due diligence is now used in the money laundering regulations, rather than the previous KYC or know your client. The old term was helpful because if you do know your client you are a long way towards mitigating money laundering risk and providing good service – the two often go hand in hand. If you know your clients well you know what is normal for them, and what doesn’t quite seem right. In estate agency of course, not only is it important to know your client, but also to do due diligence on the purchaser once an offer is accepted (assuming you’re acting as a sales agent). This can be more tricky, but you will likely have seen hundreds, if not thousands of potential purchasers and will know when something seems off.
Write it down
In compliance the adage is that if it’s not written down it didn’t happen. In dealing with AML compliance it is essential to comply and be seen to comply so that supervisors can be satisfied. HMRC will want to see well documented risk assessments, policies, staff onboarding records, training records, notes on when you’ve made a suspicious activity report and why, and notes on when you’ve decided not to submit a report. Regulatory investigations can come years after the instruction, so will you remember how you got comfortable with that risky client four years down the road? Probably not, so it is advisable to write it down.
Your staff are your first line of defence
If you are bigger than a one-man band you will be relying on your team to spot anything suspicious, and to know what to do if they spot something untoward. So it pays to make sure everyone knows why preventing money laundering is important, what their legal obligations are and what your firm’s policy is through good training. Do also make sure the training is regularly repeated, particularly for new starters and keep training records.
Keep up to date
The AML world never stays still. There are frequent updates to legislation, guidance, high risk country lists given the economic world we are all operating in. Unfortunately, this means that AML policies and training aren’t a ‘once and done’ thing but a constant Sisyphean battle of reviewing and updating. It’s a good idea to set aside some time annually during quiet periods to review your documentation to make sure it doesn’t need updating. Also keep an eye on the HMRC website and other trusted sources for updates that will prompt changes to your policies and controls.
This article was first published in Estate Agent Today.
