Commercial Property Lettings Agency Anti-Money Laundering Policy

This Anti-Money Laundering (AML) Policy is designed for Commercial Lettings Agency businesses. Its purpose is to raise awareness of money laundering risks, help prevent illicit activity, and guide staff in responding appropriately to any suspicions of money laundering.  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 HM Revenue & Customs (HMRC) guidance and HMRC recommend this is done annually. This template takes into account the classification (since 14th May 2025) of Letting Agents as “relevant firms” under the Sanctions and Anti-Money Laundering Act 2018.

Important Notice: These AML templates are EXAMPLES ONLY and are intended as a starting point. You must tailor them to reflect your business’s size, structure, and risk profile. You should always refer to the relevant anti-money laundering regulations and specific HMRC guidance. If you are unsure how to edit or adapt these templates, you must seek professional legal advice.  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.

Money Laundering 

Money laundering involves concealing the origins of criminal proceeds to make them appear legitimate.  The commercial property sector is attractive to money launderers because beneficial ownership can be obscured through corporate entities or overseas trusts. 

Commercial Letting Agents are often the first port of call in property transactions 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.

The Regulations

Lettings Agents are regulated by HMRC and 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 and The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (collectively, ‘the Regulations’). 

The Regulations require Lettings Agencies to take appropriate measures to prevent their services from being used for money laundering and terrorist financing. These obligations include:

• Implementing appropriate anti-money laundering (AML) policies and procedures;
• Conducting risk assessments;
• Carrying out customer due diligence; 
• Maintaining comprehensive records; and 
• Reporting any suspicious activity 

Financial Sanctions Checks for Lettings Agents

Financial sanctions are imposed by the United Nations or United Kingdom to restrict access to certain financial services, markets, and economic resources for specific individuals or entities. Lettings Agencies are obliged to understand and comply with financial sanctions requirements. 

The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury (the authority for the implementation of financial sanctions in the UK), maintains the official list of designated persons and issues guidance on sanctions compliance. 

Under the Regulations Lettings Agents are required to conduct sanctions checks in relation to every letting agreement regardless of the monthly amount of rent payable under the agreement.  (Since 14 May 2025, lettings agents are classified as "relevant firms" under The Sanctions and Anti-Money Laundering Act 2018.) 

What Does This Mean For Commercial Lettings Agents? 

In addition to ensuring compliance with AML regulations, Lettings Agents are required to:

• Conduct sanctions checks on all potential tenants, landlords and other relevant parties, regardless of rental value;
• Check these parties against government sanctions lists before entering into contracts and accepting payments; 
• Report to the OFSI if they know, or suspect that a party is a designated person or has breached sanctions regulations.  Reports are only required where the knowledge or suspicion arises in the course of conducting your business activities.

Failure to comply can result in significant financial penalties and imprisonment for up to seven years. The services provided by a Lettings Agencies can carry varying levels of risk. Agencies must assess and understand the specific risks that each customer presents.

Other Documents

This template policy should be read in conjunction with the following:

Commercial Property Lettings Agency Firm Wide Risk Assessment

Commercial Property Lettings Agency Customer ID and Risk Assessment

Guidance 

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

Guidance Note 

Guidance from HMRC on the Regulations can be accessed here. HMRC’s tailored guidance for letting agents can be accessed here.

The OFSI has also published guidance for lettings agents and landlords: UK financial sanctions general guidance - GOV.UK 

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 Lettings Agency Anti-Money Laundering Policy is part of Property. Just £38.50 + VAT provides unlimited downloads from Property for 1 year.