You know anti-money laundering (AML) compliance is important in the estate agent industry. But how often do you actually take a step back and ask yourself: are my AML policies up to standard? With HMRC tightening the screws and handing out hefty fines, there’s no better time than now to review your compliance framework.  

Compliance is not optional

Let’s start with some news you might’ve missed. In its latest update, Propertymark highlighted some concerning statistics: 

• HMRC fined over 200 estate agency businesses a total of £1.6 million for AML failings in just a six-month period.  

• Fines ranged from £1,500 to a jaw-dropping £50,000.  

Clearly, there’s no “one-size-fits-all” when it comes to penalties, but that’s hardly comforting. 

Propertymark has also been vocal in calling for practical guidance tailored specifically for estate agents. It’s not wrong – there’s a lot of guidance out there, but it often feels like it’s written for bankers, lawyers and conveyancers. Estate agents need industry-specific advice that speaks directly to their challenges. 

According to the professional body for the property sector: “Agents understand that they have AML duties, but 96% of our survey respondents said they would welcome more prescriptive guidance on how to meet their obligations, especially for more complex situations like identifying beneficial owners and sources of funds.” 

The basics: What should your AML policies cover? 

Let’s break down the essentials. If you want to keep HMRC happy, protect your business, and build trust with clients, at the very least, your AML policies must cover: 

1. Customer Due Diligence (CDD) procedures

This is AML 101, but it’s also where many agents slip up. You need to verify client identities thoroughly – every time. No shortcuts. Whether you’re dealing with an individual buyer or a corporate client, having a robust process for CDD is non-negotiable. The days of relying on “gut feel” to spot suspicious behaviour are long gone. 

1. Enhanced due diligence (EDD) for high-risk clients

Got a client making large cash transactions, or one based in a high-risk jurisdiction? These scenarios require EDD, which means more thorough checks and documentation. Think about it as CDD on steroids. If you don’t have a plan for this, you’re likely not compliant. 

1. Reporting suspicious activity

All staff should know what to do if they suspect something isn’t right. SARs (Suspicious Activity Reports) are your first line of defence, and everyone in your agency needs to know how and when to submit one. If only your MLRO (Money Laundering Reporting Officer) knows the process, it’s time for a refresh. 

1. Record-keeping practices

Record-keeping is a fundamental part of compliance. HMRC doesn’t just want you to identify risks; they want a paper trail. Inadequate documentation is one of the most common reasons agents get penalised. 

How to avoid common AML pitfalls

If you’re still reading, you’re likely thinking, “Okay, so what do I need to do?” Let’s examine the practical steps to transform your AML policies from theoretical to actionable. 

Avoid generic, outdated policies

Generic AML policies don’t work because they aren’t tailored to the unique risks your business faces. If your AML manual reads like a cut-and-paste job from a law firm, it’s time to roll up your sleeves and rewrite it (we can help with this!).  

Furthermore, your policies aren’t static. If they were written once and left to gather dust, they’re probably outdated. Regularly review and update them, ensuring they reflect any changes in regulation or your client base. 

Update your training

AML training is not something you do once when someone joins the team. It’s ongoing and should be dynamic. Training must also be practical and include case studies and examples relevant to estate agents. Ever heard of an agency that was fined for inadequate CDD? Use that as a case study in your training. Real-life examples make the risks tangible and help staff understand what to look for. 

Forget about recycling the same e-learning module every year. Mix things up by combining e-learning with live workshops and team discussions. Make sure your staff know exactly what to do when they spot red flags. 

Test your compliance

You need to test your AML policies to ensure they are working. One of the simplest ways to do this is checking if they’re being applied in practice.  

Is every file fully documented? Are the necessary identity checks recorded and up-to-date? If not, use this as an opportunity to reinforce training and tighten your procedures. Think of these audits as your “spot checks” before HMRC comes knocking. Trust us, it’s better to find issues internally than to have them pointed out by the regulator. 

AML for estate agents: be proactive, not reactive

As HMRC becomes increasingly strict, the real value of a robust AML policy lies in its ability to protect your business, not just from fines but from reputational damage. Let’s face it, no one wants to be known as the agency that facilitated financial crime. 

Ready to ensure your AML policies are up to scratch? 

Designed specifically for your industry, we offer tailored compliance services for estate agents. Don’t wait until you’re in the headlines for the wrong reasons. Get compliant, stay compliant, and build a business you can be proud of.