Estate Agency Anti-Money Laundering Policy

This Anti-Money Laundering (AML)Policy is designed for residential Estate 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.

Important Notice: These AML templates are an EXAMPLE 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 property sector is attractive to money launders because beneficial ownership can be obscured through corporate entities or overseas trusts. 

Estate Agents are often the first port of call in property transactions and so they are best places to identity and verify the parties to a transaction and report any suspicious activity at the outset of the transaction.

The Regulations

Estate 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 (collectively, ‘the Regulations’). 

The Regulations require Estate 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 

Failure to comply can result in significant financial penalties and imprisonment for up to seven years. 

Suitable Documents

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

Estate Agency Firm Wide Risk Assessment

Customer Identification and Risk Assessment Form for Estate Agency

Further guidance

Reference should be made to the following:

Guidance Note: AML for Residential Estate and Lettings Agency

HMRC guidance on the Regulations can be accessed here.  

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