The measures reforming anti money laundering (AML) laws set out in The Money Laundering & Terrorist Financing (Amendment) Regulations 2026 include amendments to the provisions governing estate agents and letting agents. Whilst these changes do not alter the sector's central AML responsibilities, they reinforce the expectation that property professionals apply a risk-based approach and maintain appropriate due diligence procedures.

Estate agents involved in property sales are generally required to undertake customer due diligence on both sellers and buyers. This includes verifying identities and understanding ownership arrangements where companies or other entities are involved.

These requirements apply to residential as well as commercial property transactions. Residential sales may involve lower values than some commercial transactions, but they can nevertheless present significant money laundering risks, particularly where ownership structures, sources of funds or purchasing arrangements are not readily transparent.

Estate agents must also assess transaction risks. Factors potentially raising concern may include:

• purchasers using complex corporate structures. 
• overseas entities with limited transparency. 
• unusual funding arrangements. 
• transactions that appear inconsistent with market values. 
• reluctance to provide information about ownership or funding sources. 

In residential transactions, additional indicators of risk may include the use of third parties to provide purchase funds, frequent changes in ownership, purchases made without an apparent mortgage where the source of funds is unclear, or arrangements that appear inconsistent with a purchaser's known circumstances.

Particular attention should be paid to transactions involving higher-risk jurisdictions, unusually complex ownership arrangements, or funding structures that are difficult to explain or verify.

In practice, estate agents are increasingly required to gather information that would once have been obtained only by solicitors or financial institutions.

The introduction of greater transparency requirements has increased scrutiny of property ownership, particularly where overseas entities or politically exposed persons are involved.

For estate agency businesses, AML compliance has become a significant operational responsibility rather than a purely administrative exercise. Firms are expected to maintain risk assessments, staff training programmes, internal reporting procedures and appropriate records.

Failure to comply can result in regulatory penalties, reputational damage and, in serious cases, criminal liability.