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Commercial Property Estate Agency Anti-Money Laundering Policy


This Anti-Money Laundering Policy is designed for an estate agency business dealing with commercial property to put in place a policy in order to make staff aware of money laundering, prevent money laundering taking place and assist staff if any money laundering activity is suspected. 

This template should be read in conjunction with our Commercial Property Estate Agency Firm Wide Risk Assessment and Commercial Property Estate Agency Customer Identification and Risk Assessment Form.

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”.

Although estate agents don’t handle transaction monies, they 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.

Estate agents are regulated by HM Revenue & Customs. A regulated business must comply with 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’) which requires estate agents to have a written anti-money laundering policy in place. 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 HM Revenue & Customs guidance and HM Revenue & Customs recommend this is done annually.

Estate agents are also required to put in place a number of controls and procedures to anticipate and prevent their business being used by criminals to launder money and fund terrorism. HM Revenue & Customs has a useful guide for estate agents to ensure they are compliant with the Regulations. The guidance can be found here.

Our anti-money laundering templates are an EXAMPLE ONLY and are intended to be a starting point for you to implement the requirements set out in the legislation and guidance.  You must tailor the templates to suit your own business. These templates must be read alongside the relevant money laundering regulations and specific HM Revenue and Customs guidance.

If you are unsure how to edit or adapt these templates in accordance with the relevant legislation and guidance, professional advice should be sought. 

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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