Propertymark at the table as officials shape money laundering reform

Head of Policy and Campaigns, Timothy Douglas, met senior officials at the Foreign, Commonwealth & Development Office (FCDO) on 8 December to discuss how economic crime affects the property sector, particularly the role of real estate in laundering illicit wealth and the regulatory gaps that can facilitate this activity. Meanwhile, the UK Government published its Anti-Corruption Strategy 2025, setting out plans to strengthen the UK’s defences against illicit finance.

AML written on wooden blocks next to a piles of coins

The Strategy identifies property and real estate as a continuing risk point and places renewed emphasis on transparency around beneficial ownership, enforcement of sanctions, and improved regulatory coordination.

The UK Government also confirmed that it will host an international Illicit Finance Summit in 2026, aiming to bring together policymakers, regulators and industry stakeholders to coordinate action, with a specific focus on property, sanctions, and asset-ownership transparency.

Why property remains a key focus

Immovable property and high-value assets are particularly vulnerable to abuse by corrupt actors, criminals and sanctioned individuals, especially where ownership is concealed through complex corporate or offshore structures.

Despite reforms such as the Register of Overseas Entities, the strategy identifies persistent gaps: anonymous ownership remains possible via shell companies, trusts or nominee arrangements, complicating enforcement. Public perception echoes this risk, with a majority believing that overseas corruption affects UK housing markets, a concern many within the sector share.

Previous National Risk Assessments have estimated that as much as £10 billion could be laundered through the UK property sector every year, underscoring why property remains a target for illicit actors.

Risk managment, wooden block stack
13 Oct 2025
£10 billion could be laundered through the UK property sector every year

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.

What Propertymark raised with the FCDO

In line with our policy paper and previous campaign activity, we advocated for reforms that both deter wrongdoing and support compliance by legitimate agents.

Douglas highlighted that without statutory regulation of property agents, enforcement and expectations remain inconsistent and create avoidable gaps for illicit activity to persist. In particular, he raised our longstanding concerns about the AML threshold for lettings, noting that high-risk transactions may currently fall outside supervision.

Checklist with red pen
28 Feb 2025
Lettings Spotlight: financial sanctions reporting obligations

Letting agency businesses across the UK need to work to a new framework from 14 May 2025 under the Sanctions and Anti-Money Laundering Act 2018, and it is vital that every agent understands the rules and adjusts working practices and systems accordingly. Through our vast network of members, some confusion has been highlighted around the rules, and we have produced resources to navigate the requirements.

It is also important that AML, sanctions and beneficial-ownership reporting frameworks are designed specifically for property agency work, not just adapted from the banking or legal sectors, so that good-faith compliance is clear, proportionate and enforceable.

Summit focus aligns with sector priorities

Officials confirmed that transparency within property and real estate markets, particularly in relation to beneficial ownership rules in British Overseas Territories, will be a key priority for the 2026 summit.

We have repeatedly pressed for improvements, particularly around ownership transparency, cross-border compliance frameworks and clarity in enforcement expectations.

The direction of travel for ’26 and beyond

While no immediate legislative changes have been introduced, the policy direction is clear: scrutiny is increasing, documentation will become more important, and regulatory oversight is likely to become more consistent across the sector.

Future reforms may require more rigorous identity and beneficial-owner verification checks, especially where clients are purchasing through corporate or international structures. AML supervision in lettings may also be expanded beyond the current threshold-based model. Enforcement agencies are expected to be given greater resources and intelligence-sharing capabilities, and record-keeping expectations may become more prescriptive.

These developments sit alongside wider regulatory change, including material information guidance, home buying and selling reform, and implementation of the Renters’ Rights Act, where transparency and due diligence are becoming routine operating expectations.

Supporting members

As the sector navigates a changing enforcement landscape, Propertymark continues to engage with regulators and policymakers to ensure proposals are proportionate and workable in practice.

Members can access AML guidance, training and compliance support through the Propertymark website to help meet current Money Laundering Regulations and sanctions requirements.

London properties with blurred traffic
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.