A clear warning for the sector
The latest fines serve as a reminder that AML compliance is not optional. HMRC continues to focus on the property sector as a high-risk area for economic crime and has made clear it will continue to act against agents who fail to meet their legal obligations.
Propertymark urges all agents to review their registration status, check their systems and controls, and seek professional support where needed. Getting compliance right not only avoids penalties but helps protect the integrity of the UK property market.
Why are agents being fined?
HMRC has confirmed that most penalties were issued because businesses were trading while not registered for AML supervision. In total, 332 of the penalties were for agents and other businesses failing to register when legally required to do so.
Other common compliance failures include:
- Not renewing AML registration on time
- Inadequate customer due diligence checks
- Poor record keeping
- Failure to maintain up-to-date risk assessments and policies
In some cases, penalties were reduced where businesses voluntarily disclosed errors. However, HMRC has been clear that ignorance of the rules is not a defence.
Who needs to register?
High Value Dealers (HVDs): Any business or sole trader that accepts or makes high-value cash payments of 10,000 euros or more (or the equivalent in any currency) in exchange for goods. This includes payments made in notes, coins, or traveller’s cheques. It also applies when a customer deposits cash directly into a bank account or pays via a third party.
This encompasses single cash payments of 10,000 euros or more for goods, several cash payments for a single transaction totalling 10,000 euros or more (including instalments or payments on account), and cash payments totalling 10,000 euros or more that appear to be broken down into smaller amounts to avoid the high-value payment limit.
Businesses Dealing in Goods: This includes agents or auctioneers who do not own the goods, transactions where the goods do not change ownership (e.g., sale or return), and transactions involving goods and services where the open market value of the goods is 10,000 euros or more.
Art market participants: A firm or sole practitioner who, ‘by way of business’, trades in, or acts as an intermediary in, the buying or selling of works of art where the transaction value (or a series of linked transactions) is 10,000 euros or more.
Estate Agency Businesses (EABs): A firm or sole practitioner that carries out estate agency work as defined by the Estate Agents Act 1979. This includes UK-based EABs dealing with overseas property and EABs based abroad if their customer is based in the UK.
Download our AML guide for sales agents →
Letting Agency Businesses (LABs): A firm or sole practitioner who, or whose employees, carry out letting agency work when an agreement is concluded for the letting of land for a term of a month or more, and at a rent which, during at least part of the term, is or is equivalent to a monthly rent of 10,000 euros or more. This applies to both residential and commercial properties.
LABs must register with HMRC for anti-money laundering supervision if they handle client money, including fees, deposits, and rent, and if their rental activity exceeds the threshold.
Why must agents stay compliant?
The Money Laundering Regulations require agencies have procedures to anticipate and prevent money laundering. This reduces the risk that criminals exploit businesses for financial crime.
Steps agents must take include:
- Develop a written, up-to-date risk assessment of the location operating in, customers and the value of transactions undertaken
- A written policy statement and procedures to show how the business will manage the risks of money laundering
- Train and support staff to understand and implement these policies
- Ensure procedures and audit processes are applied to all branches in or outside the UK
- Appoint a nominated officer (Money Laundering Reporting Officer - MLRO) to report suspicious activity to the National Crime Agency (NCA) and a Deputy Money Laundering Reporting Officer
- Ensure suitable control measures are in place
- Notify HMRC of any material changes, for example a change of MLRO
Failing to meet these obligations can result in financial penalties, reputational damage and, in serious cases, criminal sanctions.
An important tip is to ensure that contact email addresses for HMRC notifications are to a generic email rather than to an individual so the business does not miss important updates and messages.
Read HMRC guidance for estate and letting agents →
Read HMRC guidance for high value dealers →
Read HMRC guidance for art market participants →
Download AML compliance checklist →
How Propertymark is supporting members
Our ongoing campaign calls for clearer, more practical AML guidance that reflects how property agents operate in practice. We have consistently advocated for improved supervision, better information sharing and proportionate enforcement.
Alongside this policy work, we provide members with practical support to help them comply, including:
- AML guidance and fact sheets
- Training and qualifications
- Regular updates on regulatory changes and enforcement trends via articles, emails, and social media
- Templates and best practice resources to support compliance systems
Agencies that subscribe to Company Advantage benefit from AML checks, ensuring they can remain compliant while keeping transactions moving efficiently. These checks provide instant verification, allowing agents to onboard clients quickly and reduce delays in property transactions.
Furthermore, our Compliance audit support offers a friendly experience combined with 1:1 advice that will help agents navigate complex government regulations, avoid costly fines, and safeguard against uncertainty.
Anti-money laundering (AML) training and resources
We have created a number of resources, forms and training options for agents and auctioneers to comply with their Anti-Money Laundering obligations.
