Risk Assessment

Commercial Property Estate Agency Firm Wide Risk Assessment


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 as amended by The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (‘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 October 2020 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.  If you are unsure as to the risks your business may be exposed to or how to complete this template, you should seek professional advice.  

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 Firm Wide Risk Assessment is intended as a starting point to assist you in implenenting the requirements set out in the Regulations and guidance.   

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. 

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