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Letting Agents and Anti-Money Laundering

Anti-Money Laundering (High Value Lettings)

The documents in this subfolder are for use by Residential Lettings Agencies that deal with high value lettings at a rent which during at least part of that period is, or is equivalent to, a monthly rent of 10,000 euros or more.

Under The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (‘the 2019 Regulations’) letting agents dealing with high value lets are required to comply with anti-money laundering regulations.

As a letting agent, if you fall within the following definition, you will need to be registered with HM Revenue & Customs and, as a regulated business you must put in place a number of policies, controls and procedures to anticipate and prevent your business being used by criminals to launder money and fund terrorism when dealing with monthly rents of 10,000 euros or more.

“Letting agent” means a firm or sole practitioner who, or whose employees, carry out letting agency work, when carrying out such work.

“letting agency work” means work:

(a) consisting of things done in response to instructions received from:

(i) a person (a “prospective landlord”) seeking to find another person to whom to let land, or

(ii) a person (a “prospective tenant”) seeking to find land to rent, and

(b) done in a case where an agreement is concluded for the letting of land:

(i) for a term of a month or more, and

(ii) at a rent which during at least part of the term is, or is equivalent to, a monthly rent of 10,000 euros or more.

The subfolder contains a template Lettings Agency Firm Wide Risk Assessment, a template Lettings Agency Anti-Money Laundering Policy and a template Lettings Agency Customer Identification Form and Risk Assessment Form.

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. 

Guidance from HMRC on the money laundering regulations can be accessed here.  HMRC will produce specific guidance for letting agents on money laundering supervision but this has not yet been published after more than a year since the Regulations came into force.  

Failure to comply with the 2019 Regulations can result in civil penalties or criminal prosecution. Senior managers and nominated officers can also be found personally liable for a breach of these regulations.

These Anti-Money Laundering Documents for High Value Lettings are part of the Property Documents Folder. Just £35.00 + VAT will provide you with 1 year's unlimited access to download all/any documents from the Property Folder.

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