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.
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 HMRC. 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 HMRC guidance
and HMRC 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. HMRC has a useful guide for estate
agents to ensure they are compliant with the Regulations. This guidance was
updated in October 2020 and can be found
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 Commercial Property Estate 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.
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.
This document is in open format. Either enter the requisite details in the
highlighted fields or adjust the wording to suit your purposes.
Once you have subscribed to the appropriate document folder click on the
“Download Document” button below. You will be asked what you want to do
with the file. It is recommended that you save the document to a location
of your choice prior to viewing.