Commercial Property Estate Agency Firm Wide Risk Assessment

This Estate Agency Firm Wide Risk Assessment Form is designed for use by commercial Estate Agents dealing with commercial property to assess the risks of money laundering and terrorist financing to which its business may be subject. 

Important Notice: The anti-money laundering templates are an EXAMPLE ONLY and are intended to be a starting point to help you implement the requirements set out in the legislation and guidance. You must tailor these templates and documents to reflect the nature, size, and risk profile of your own business. These templates must be read alongside the relevant money laundering regulations and specific HM Revenue & Customs guidance. If you are unsure how to adapt or implement the templates appropriately, professional legal or compliance advice should be sought. This template does not replace your responsibility to ensure you are adequately trained in AML compliance or to consult and adhere to the official guidance issued by HM Revenue and Customs (HMRC) and HM Treasury.

The Regulations

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’), Estate Agents are required to have a written risk assessment in place.  This assessment must be reviewed at least annually. It helps agents understand the specific risks facing their business and ensures appropriate mitigation measures are in place.

HM Revenue & Customs (HMRC), the supervising authority for Estate Agents dealing with high value lets, may request a copy of your risk assessment at any time, and you are obliged to provide it.  

Estate Agents covered by the Regulations must collect information in order to prepare their risk assessment. This may include reviewing historic files, consulting with staff, or conducting internal questionnaires. The method and sources of information used must be clearly documented and made available to HMRC upon request. 

Failure to comply with the Regulations may lead to civil penalties or criminal prosecution. Senior managers and nominated officers may also be held personally liable for any breaches.

Suitable Documents

This template can be used in conjunction with the following documents:

Commercial Property Estate Agency Anti-Money Laundering Policy

Commercial Property Estate Agency Client Identification and Risk Assessment Form

Agents must consider and document the specific money laundering and terrorist financing risks relevant to their own business model and operations. 

Guidance

Reference can be made to the following for guidance on the Regulations and compliance:

HMRC guidance on the Regulations can be accessed here.  

HMRC sector-specific guidance for Letting Agents can be accessed here.

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.

Commercial Property Estate Agency Firm Wide Risk Assessment is part of Property. Just £38.50 + VAT provides unlimited downloads from Property for 1 year.