Risk Assessment

Commercial Property Estate Agency Firm Wide Risk Assessment

PROP.EST.91

This Template Firm Wide Risk Assessment is for use by estate agents dealing with commercial property to assess the risks of money laundering and terrorism financing to which its business may be subject.

Under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (‘the Regulations’) all regulated businesses must carry out a risk assessment. The risk assessment must be in writing and subject to annual review. HMRC (the supervising authority for estate agents) can request a copy of this risk assessment which you must provide to them.

Under the Regulations estate agents are required to gather information in order to prepare their risk assessment. For example, agents may review old files or discuss risks with staff or ask staff to complete a questionnaire. How and what information is gathered must be recorded and provided to HMRC upon request.

Estate agents must review all guidance and information provided by HMRC to assist with anti-money laundering. HMRC has produced a useful guide for estate agents to ensure they are compliant with the Regulations. This guidance was updated in May 2019 and can be found here.

Estate agents must consider the risk factors that their own business may be exposed to and identify these in their assessment. This Template has a list of risks which estate agents are likely to be exposed to. The list is not exhaustive. You must tailor these to your specific business and expand on the risks where relevant. The HMRC guidance has further information as well as links to other sources including the National Risk Assessment.

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