Commercial Property Lettings Agency Customer ID and Risk Assessment

This Commercial Lettings Agency Customer Identification and Risk Assessment Form is designed for use by commercial Lettings Agents when checking and verifying the identity of a new customer for Anti-Money Laundering (AML) purposes. It can also be used to verify the identity of other contracting parties and any beneficial owners. A separate form should be completed for each individual. This template has been updated in line with the classification of Letting Agents as “relevant firms” under the Sanctions and Anti-Money Laundering Act 2018, effective from 14th May 2025.

Important Notice: This form is EXAMPLE ONLY and are intended as a starting point. You must tailor the form 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. 

The Regulations 

Lettings Agents are regulated by HM Revenue & Customs (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 ('the Regulations').  Under the Regulations Lettings Agents are required to identify and verify their customers, other parties to the transaction, and any beneficial owners.

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.

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 required 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 current AML Regulations, Lettings Agents are required to carry out sanctions checks only where the  monthly rents exceed 10,000 euros per month.  However, from 14 May 2025, Lettings Agents will be classified as "relevant firms" under The Sanctions and Anti-Money Laundering Act 2018. 

What Does This Mean For Lettings Agents? 

In addition to ensuring compliance with AML regulations, Lettings Agents will be 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. 

Customer ID and Risk Assessment

The Form prompts the Agent to check the client’s identity documents proving a client’s name and address. A list of acceptable documents appears as List A and List B in the form.  

The form also contains a risk assessment and certification which must be completed and signed by the agent to confirm they have completed the necessary identity verification check and risk assessment.  Attached to the form are examples of suspicious activity which can be used as reference. If there any concerns about anti-money laundering these have to be reported to the MLRO.

This form is suitable for standard due diligence.  Enhanced due diligence may need to be undertaken for high risk individuals and transactions.  Agents must consider and document the specific money laundering and terrorist financing risks relevant to their own business model and operations. 

Other Documents

This template should be read in conjunction with the following:

Commercial Property Lettings Agency Firm Wide Risk Assessment

Commercial Property Lettings Agency Anti-Money Laundering Policy

For Company clients please see: Commercial Property Estate Agency Customer ID and Risk Assessment (Company Client)

Guidance

Reference should be made to the following: 

Guidance Note: AML for Commercial Estate and Lettings Agency

HMR has produced a useful guide for Estate Agents to ensure they are compliant with the Regulations. The guidance can be found here.

This Lettings Agency Customer Identification and Risk Assessment Form is in open format. Either enter the requisite details in the highlighted fields or adjust the wording to suit your purposes.

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