Commercial property transactions can present additional AML risks compared to residential property transactions because ownership structures involved are often more complex.

Such commercial transactions may involve:

• investment vehicles 
• corporate groups
• overseas investors 
• pension arrangements 
• joint ventures 

Estate agents dealing with commercial property may therefore need to conduct more extensive enquiries regarding beneficial ownership and funding arrangements.

Particular attention may be required where transactions involve higher-risk jurisdictions or unusually complicated ownership structures. The 2026 amendments to the law (set out in The Money Laundering and Terrorist Financing (Amendment) Regulations 2026) strengthen the emphasis on identifying and assessing unusually complex or unusually large transactions as potential indicators of elevated risk.

Although commercial transactions may involve more complex ownership arrangements than residential transactions, estate agents should not assume that residential transactions present lower risks. The appropriate level of scrutiny should always be determined by the circumstances of the particular transaction.