Thousands of estate agents across the UK may now be in breach of anti-money-laundering (AML) regulations following sweeping updates introduced by HMRC in September, according to compliance technology firm Coadjute.
The new guidance, published on 9 September, represents one of the most significant AML overhauls in recent years.
The word “must” appears more than 200 times, transforming many previously recommended checks into legal obligations.
Crucially, agents are now required to address a detailed list of 34 named risk indicators in their Business Risk Assessments (BRA) and Policies, Controls and Procedures (PCPs).
ENFORCEMENT FINES
Any firm that has not updated its documentation and onboarding processes since the changes came into force is likely to be non-compliant – and could face fines of up to £158,000, based on recent HMRC enforcement actions.
The revised framework explicitly highlights red-flag risk patterns such as super-prime property anomalies, SPVs, offshore ownership, intermediaries, remote onboarding and third-party payers.
HMRC has also clarified that widely used digital ID tools and sanctions look-ups are no longer sufficient on their own to meet AML requirements.
GROWING CONFUSION
Coadjute’s Chief Operating Officer, John Reynolds (main picture), reckons confusion across the industry has grown since the update.
He says: “Agents are receiving audit requests and warning notices, and many are realising their existing AML files and policies simply don’t meet the new benchmark.
“If you’re still doing what you’ve always done, you may now be breaking the law.”
Reynolds urged agents to professionalise or outsource their AML procedures as scrutiny increases.
He adds: “The new rules make ad-hoc compliance impossible to defend. Getting it right protects not just your licence but your brand.”
