Letting Agents AML Policy

This Anti-Money Laundering Policy is designed for a lettings agency business dealing with high value residential lettings (at a monthly rent of 10,000 euros or more) to put in place a policy to make staff aware of money laundering, prevent money laundering taking place and assist staff if any money laundering activity is suspected.

Under The Money Laundering and Terrorist Financing (Amendment) Regulations 2019, from the 10 January 2020, letting agents dealing with high value lettings are being brought into the scope of money laundering regulations.

Money laundering is the process of moving illegally acquired cash through financial systems so that it appears to come from a legitimate source. Criminals will try to conceal the origin and true ownership of the proceeds of their activities in order to turn the money from “dirty” to “clean”.

Letting agents are often the first port of call in a property transaction and so they are best placed to identify and verify the parties to a transaction and report any suspicious activity at the outset of the transaction.

Under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended by The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (‘the Regulations’) letting agents dealing with high value residential lettings will need to have a written anti-money laundering policy in place from the 10 January 2020.

A copy of the anti-money laundering policy must be given to all staff. Staff must also receive anti-money laundering training. The anti-money laundering policy should supplement staff training. This policy should be reviewed regularly to ensure that it complies with HMRC guidance and HMRC recommend this is done annually.

You must read the Regulations and the HMRC guidance if you are a regulated business to ensure that you are complying fully with the legislation. This template Lettings Agency Anti-Money Laundering Policy is intended as a starting point to assist you in implementing the requirements set out in the Regulations and guidance. You will need to tailor our template policy to your specific business and practice in accordance with the guidance and Regulations.

Guidance from HMRC on the money laundering regulations can be accessed here.  We expect HMRC will produce specific guidance for letting agents on money laundering supervision in due course but at the time of writing this has not yet been published. 

Failure to comply with the Regulations can result in civil penalties or criminal prosecution. Senior managers and nominated officers can also be found personally liable for a breach of the Regulations. If you are unsure how to edit or adapt this template policy in accordance with the Regulations and guidance, professional advice should be sought.

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