The UK Government has published its Anti-Money Laundering and Asset Recovery Strategy 2026–2029 to make it harder for criminals to move, conceal, and benefit from illicit funds.
Backed by at least £550 million of investment between 2026 and 2029, the strategy focuses on three principles: Target, Integrate and Empower. This means concentrating resources on the highest risks rather than low-value activity, improving information sharing, and giving supervisors and law enforcement better technology, skills and powers.
For property agents, the direction is significant. Property has long been recognised as vulnerable to money laundering because criminals can use transactions and ownership structures to integrate illicit wealth into the legitimate economy. The strategy itself highlights a case involving attempts to purchase high-value London property, where anti-money laundering Know Your Customer checks helped trigger intelligence that ultimately contributed to an investigation.
Letting agent requirements could change
One of the most relevant commitments for the sector is a planned consultation on the current scope of AML regulation for letting agents.
Currently, letting agency businesses fall within the Money Laundering Regulations where they undertake qualifying work involving monthly rents of £10,000 or more. The new strategy says the government will consult during 2026/27 on whether changes are needed to address identified illicit finance risks involving letting agents. Depending on the outcome, secondary legislation could follow in 2027/28, with changes potentially implemented during 2028/29.
Consultation to assess how to address illicit finance risks within the property development, offshore virtual asset service provider, football, crowdfunding, and antiques and antiquities sectors and changes to the current scope of regulation for letting agents and higher-risk high-value goods dealers.
This does not mean that the threshold or scope has changed now, but it signals that the current regulatory perimeter is being actively reconsidered.
Property developers will also come under scrutiny. They currently sit outside the regulated sector but are specifically identified for consideration as part of the same consultation.
A move towards intelligence-led supervision
The strategy aims to make AML supervision more effective and more intelligence-led, while reducing unnecessary ‘box-ticking’.
HMRC will continue encouraging supervised businesses to take a risk-based approach, alongside greater collaboration and information sharing. Considerations are being put forward to strengthen supervisory enforcement powers, including those relating to unannounced visits and director accountability.
Technology could make compliance easier
There is also recognition that stronger AML controls should not automatically mean more administration.
The strategy commits the government to exploring how digital identity and artificial intelligence can streamline AML compliance, whilst HMRC will promote good practice in the use of technology and AI among supervised businesses.
Alongside this, the Suspicious Activity Reports regime will be reviewed for opportunities to reduce low-value activity, and further changes to the Money Laundering Regulations will be considered with the same objective.
The ambition is a system that focuses agents’ and supervisors’ attention on genuine risk rather than compliance activity that provides little intelligence or protection.
Propertymark supports members with AML compliance
Our resources help members navigate areas including customer due diligence, risk assessments, identifying beneficial ownership, enhanced due diligence, record keeping and recognising and reporting suspicious activity. Members can also access guidance, training and support to help ensure procedures remain appropriate as legislation and HMRC expectations develop.
Anti-Money Laundering
We have created a number of resources, forms and training options for agents and auctioneers to comply with their Anti-Money Laundering obligations.
For agents, a key starting point is understanding the risks within their own business. HMRC makes clear that a generic approach is not sufficient: estate agency businesses must undertake their own risk assessment, taking account of the customers they deal with, the services they provide and the risks relevant to their activities.
We will respond to the forthcoming consultation on the scope of AML regulation for letting agents, using member evidence to ensure any changes are proportionate, practical and reflect how the sector operates. We will continue to engage with the UK Government and HMRC as the strategy is implemented, while supporting members with the guidance, training and resources they need to meet their AML obligations.
