What are the reporting obligations?
Businesses categorised as ‘relevant firms’ under financial sanctions rules must report when they know or suspect:
- A person is a designated individual, or
- A breach of financial sanctions regulations has occurred.
From May 2025, all letting agents will be added to this list, regardless of the rental value of the properties they handle. OFSI has published new guidance for letting agents and plans further industry engagement ahead of implementation.
High-value dealers (HVDs) and art market auctioneers handling items or transactions worth €10,000 or more will also become relevant firms from May 2025. The existing guidance for high-value dealers and art market participants has been updated to reflect this.
When should a report be made?
Letting agents must submit a report to OFSI if they have evidence or reasonable suspicions that a client has breached financial sanctions regulations, and this suspicion arises when a landlord instructs the agent, or a landlord accepts a tenant’s offer. There is no obligation to report on tenants before their offer is accepted.
HVDs and auctioneers must make a report if they have evidence or reasonable suspicions about any person they deal with .
To make a report, the agents, HVDs, and auctioneers must complete a Compliance Reporting Form and email it and any supporting documents to OFSI.
Full instructions are available on GOV.UK →
How is this different to AML regulations?
Since January 2020, letting agents managing properties with monthly rents exceeding €10,000 have been required to register with HMRC and conduct customer due diligence under AML regulations. Suspicious transactions related to money laundering, terrorist financing, or proliferation financing must be reported to the National Crime Agency.
Propertymark has long campaigned for the €10,000 threshold to be removed so that all property agents are subject to AML supervision and have the same reporting requirements. This would make it easier for agents to understand and comply with the regulations.
Support for members
Propertymark has a range of training for all agents, plus a fact sheet and resources to help its members comply with current regulations.
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.
Propertymark has long argued that the existing threshold for AML supervision for letting agents should be removed to reduce the risk of cash payments being used to ‘clean’ dirty money.
Whilst we recognise that the UK Government wants to tackle financial sanctions breaches that are occurring below the threshold, this is a missed opportunity to level the playing field for letting agents in terms of AML supervision, Customer Due Diligence and financial sanctions reporting obligations.
HM Treasury must continue to engage widely with the sector to avoid misinformation and confusion among agents and financial institutions.
Furthermore, we will continue to urge HM Treasury to reflect on the impact of the proposals and work to remove the threshold within the Anti Money Laundering Regulations to bring greater clarity to the sector and ensure it is less vulnerable to criminal activity.
