Estate Agency Customer Identification and Risk Assessment Form 
This Estate Agency Customer Identification and Risk Assessment Form is designed for use by Estate 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.
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
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 ('the Regulations'). Under the Regulations Estate 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.
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:
Estate Agency Anti-Money Laundering Policy
Estate Agency Firm Wide Risk Assessment
Guidance
Reference should be made to the following:
Guidance Note: AML for Residential 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 Estate 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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