UK estate agency businesses must register with HMRC for AML supervision before trading and carry out customer due diligence on both the buyer and the seller once an offer is accepted. Letting agency businesses are in scope for qualifying lettings — broadly, a term of a month or more at a rent equivalent to £10,000 or more per month. Trading without registering is a criminal offence.
Who is supervised, and by whom
For estate agency businesses, the AML supervisor is HM Revenue & Customs (HMRC), which runs inspections, compliance checks and enforcement. This differs from banking, where the FCA supervises AML. The government has announced the FCA will become the single AML supervisor for professional services (legal, accountancy, trust/company services) — but this does not extend to property agency. Estate and letting agents remain registered with, and supervised by, HMRC.
Are letting agents covered?
Letting agency businesses came into the Money Laundering Regulations on 10 January 2020, but only for qualifying lettings. A letting is in scope where the term is a month or more and the rent is, or is equivalent to, a monthly rent of £10,000 or more. That threshold was set in sterling by amendment regulations in force from 30 June 2026 — older guidance quoting a euro figure is out of date. Where a letting meets the threshold, due diligence applies to both the landlord and the tenant.
Your core AML obligations as an estate agent
- Register with HMRC before you trade and keep registration and fees current. Operating unregistered is a criminal offence.
- Carry out a firm-wide risk assessment and document it.
- Apply customer due diligence on buyer and seller once an offer is accepted — identify, verify, risk-rate.
- Screen against sanctions and PEP lists, and keep that screening current as lists change.
- Apply enhanced due diligence where risk is higher — unusual structures, high-risk jurisdictions, PEPs.
- Keep records of checks, and report suspicion via a SAR to the National Crime Agency where required.
- Monitor and refresh — AML is ongoing, not a one-off at instruction.
Key takeaway
A point firms often miss: once an offer is accepted, due diligence applies to both parties — buyer and seller — not only the party that instructed you. Estate agents sit near the very start of the money-laundering chain, which is exactly why HMRC scrutinises the sector.
What changed in 2026
Two developments matter this year. First, the UK consolidated its sanctions designations into a Single UK Sanctions List, launched in early 2026 — a single searchable source that adds a clear screening obligation across property. Firms whose workflows predate 2026 should confirm this screening is built in. Second, the £10,000 letting threshold was fixed in sterling from 30 June 2026, replacing the older euro reference.
Enforcement is rising — fast
HMRC’s appetite for enforcement against property agents has grown steeply. In a recent reporting period HMRC issued 170 penalties to estate agency businesses totalling more than £835,000, most linked to firms that traded without registering on time. Reported figures also point to a large year-on-year rise in enforcement actions and a high non-compliance rate among firms inspected. The message: registration, due diligence and documentation must withstand a review today, not eventually.
Figures cited reflect published HMRC enforcement reporting at the time of writing and should be confirmed against the current HMRC record before you rely on them.
Where estate agents most often go wrong
- Trading before registering with HMRC — the single most common trigger for a penalty.
- Checking only one side of the transaction instead of both buyer and seller.
- Treating AML as a tick-box — having a policy but not applying it consistently.
- Stale screening — not updating sanctions/PEP checks as lists change, including the new consolidated list.
- Weak records — unable to evidence what was checked, when, and by whom.
Build a compliant process without slowing down sales
The tension every agency feels is compliance vs speed — chains stall while checks are chased. The practical answer is to make checks fast and consistent by design: a structured digital flow lets buyers and sellers verify identity from their phone in minutes, runs sanctions and PEP screening automatically, records everything for HMRC, and gives every branch the same process rather than letting checks drift between staff.
Run buyer and seller AML checks in minutes — from any branch
OnBoardNow captures ID, verifies identity with a liveness-tested match, screens against AML, PEP and sanctions lists, and keeps a full HMRC-ready audit trail — in one flow built for property.Book a demo →
Frequently asked questions
Do estate agents legally have to do AML checks?
Yes. Estate agency businesses are ‘relevant persons’ under the Money Laundering Regulations 2017 and must register with HMRC and apply customer due diligence. Trading unregistered is a criminal offence.
Do I check the buyer, the seller, or both?
Both. Once an offer is accepted, due diligence applies to the seller and the buyer — not only the party that instructed you.
Are letting agents included?
For qualifying lettings only — broadly a term of a month or more at a rent equivalent to £10,000 or more per month. Then due diligence applies to both landlord and tenant.
What are the penalties for non-compliance?
HMRC can issue civil fines and, in serious cases, pursue prohibitions or prosecution. Recent enforcement includes 170 estate-agency penalties totalling over £835,000 in a single period.
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