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The 2025 National Risk Assessment (NRA) has once again placed the property sector in the spotlight as one of the most attractive ways for criminals to conceal illicit wealth. Complex ownership structures, offshore companies, and opaque trusts continue to disguise the identity of the individuals behind transactions, with both residential and commercial sales and lettings vulnerable.
HMRC has clawed back £107 million in unpaid taxes from buy-to-let landlords in 2024/25, the highest annual total on record. The recoveries were made through the Let Property Campaign (LPC), HMRC’s disclosure scheme for landlords with undeclared income, and show a doubling of repayments compared with three years ago.
We have responded to the Competition and Markets Authority (CMA) on its draft price transparency guidance under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). From 6 April 2025 the DMCCA replaced the Consumer Protection from Unfair Trading Regulations, so the CMA’s approach will shape day‑to‑day advertising for every agent. Our message is clear: property is different, and the guidance must reflect that.
This guidance note helps members understand the steps they should take when a client requests payments to be made into a new account. This will support agents in protecting landlords who may have been compromised and in avoiding potential penalties from HMRC.