Compliance firm Smart Compliance has launched a new tool aimed at helping estate and letting agents build bespoke anti-money laundering (AML) policies that can stand up to HMRC scrutiny.
The product, called Risk Navigator, is designed to guide agencies through the process of creating a tailored Business Risk Assessment and AML policy, rather than relying on generic templates.
It walks users through key areas regulators expect to see addressed, including client profiles, transaction risks, geographic exposure and internal procedures, with prompts to ensure policies reflect how the business actually operates.
The move comes as regulatory pressure on the property sector continues to increase, with HMRC placing greater emphasis on whether firms can demonstrate a genuine understanding of their own risk profile.
MONEY LAUNDERING REGULATIONS
Agents are required under the Money Laundering Regulations to maintain policies and procedures that are specific to their business, but many are still relying on off-the-shelf templates that fail to meet that standard.
According to Smart Compliance, this is increasingly being exposed during audits, where inspectors are testing whether documented processes match real-world activity.
The gap between a generic policy and actual practice is becoming a key area of enforcement risk, with firms facing potential fines, remedial action and reputational damage if they cannot demonstrate compliance.
REGULATORY RISK
Amy Shields (main picture), Commercial Director at Smart Compliance, says: “AML documentation is still treated in some parts of the industry as a box-ticking exercise.
“But it is one of the first things reviewed in an audit, and the standard being applied has moved on considerably.
“The issue is never whether a policy exists – it is whether that policy reflects how the business actually operates.
“Templates create a gap between what is written and what happens in practice. That gap is where regulatory risk lives.”





