Estate Agent Anti-Money Laundering updates 2025
On 9 September 2025, HMRC published an updated risk assessment called “Understanding risks and taking action for estate agency businesses”.
Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations), estate-agency businesses (EABs) must carry out a risk assessment of money-laundering, terrorist financing and proliferation financing for each transaction.
The updated guidance emphasises that the property market remains one of the highest risk sectors for money laundering in the UK.
For estate agents, these updates mean two things:
- Your risk assessment must reflect these updated characteristics and indicators.
- You must ensure your policies, controls and procedures are aligned and proportionate to your business size, nature and delivery channels.
Key risk areas and indicators for estate agents
1. Money-laundering risk
- Property transactions are attractive for laundering because of large sums, rising values, and difficulty tracing funds.
- Residential property is assessed as higher risk than commercial property, due to higher turnover, easier resale, and use for living/accommodation.
- “Super-prime” properties (HMRC’s benchmark: £5m+ in London/South East, £1m+ elsewhere) carry especially high risk.
- Key customer/transaction risk indicators include but not limited to:
- Customer profile not aligned with property price or type (for example low income buyer buying large property).
- Unexplained relationships between buyers and sellers.
- Complex or opaque corporate structures, offshore entities or trusts
- Property price substantially above or below market value without a credible explanation.
- Use of virtual offices or multiple intermediaries, cash payments, payments from third parties, and quick resales.
2. Terrorist-financing risk
- Though the estate-agency sector is assessed by the national risk assessment as low risk for terrorist financing, it remains vulnerable because of its overlap with money-laundering processes.
- Indicators to watch for:
- Customers or entities linked to proscribed terrorist organisations.
- Customers from or linked to high geography risk jurisdictions (including certain offshore jurisdictions).
3. Proliferation-financing risk
- This covers financing of chemical, biological, radiological or nuclear weapons.
- Risk indicators include: property used for the manufacture of dual-use goods; obscure ownership structures; links to sanctioned regimes
Free AML risk assessment template
What estate agents should do following these updates
1. Review your risk assessment
- Ensure your written risk assessment explicitly addresses money laundering, terrorist financing and proliferation financing risks.
- Incorporate factors such as: customer type, geographic risk, services offered, delivery channels, transaction size/frequency.
- Include all the latest HMRC indicators in your assessment.
2. Update your policies, controls & procedures (PCPs)
- Identify higher risk scenarios and apply enhanced due diligence (EDD) accordingly (e.g., overseas trusts, shell companies, high-risk third-country links).
- Embed customer due diligence (CDD) steps aligned with these indicators (e.g., verifying beneficial owners, source of funds and wealth, identifying PEPs).
- Ensure your staff are trained, your systems flag suspicious activity, and there is ongoing monitoring of customer relationships/transactions.
3. Document and evidence your compliance
- Keep written records of your risk assessments, the basis for your controls, the due diligence you applied and decisions taken.
- Be able to demonstrate to HMRC on request that you have considered the national risk factors and your business-specific risks.
- Review your processes if your business changes (e.g., new service line, geographical expansion, new delivery channel).
4. Leverage technology and external support
- Consider integrating compliance tools (digital ID verification, AML screening, KYC platforms) to streamline customer due diligence and monitoring.
- Use specialist advice if your business handles higher-risk transactions (e.g., ultra-high-value properties, complex corporate purchasers).
- Stay alert for updates to sanctions lists, high-risk jurisdictions, and regulatory guidance.
Final thoughts
Unfortunately the regulatory burden being placed on agents is not letting up and this HMRC update reinforces that compliance isn’t optional, it’s a must for every transaction.
Your risk assessment must keep pace with your business. Your processes must reflect the risks. And you must be able to demonstrate you’ve taken action.
If you’d like help navigating these changes, reach out and we’ll help you make sense of the noise.
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