Estate agency guidance for money laundering supervision- Part 1

If you are supervised by the HMRC for anti-money laundering purposes, you will need to meet requirements under the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017. A firm engaging in estate agency work must comply with the Regulations.

Senior managers Remember that senior managers of a regulated business are responsible for the oversight of meeting the Regulations and can be held personally liable if they do not take the steps necessary to protect their business from money laundering and terrorist financing.

A senior manager is an employee who has the authority to make decisions that affect a business’s exposure to money laundering and terrorist financing risk. Examples include:

  • a director

  • manager

  • company secretary

  • chief executive

  • member of the management body, or someone who carries out those functions

  • any partner in a partnership

  • a sole proprietor

Minimum requirements Senior managers must:

  • identify, assess and manage effectively, the risks that their business may be exploited to launder money or finance terrorists

  • take a risk-based approach to manage these risks that focus more effort on high risks

  • appoint a nominated officer to report suspicious activity to the National Crime Agency

  • devote resources to address the risk of money laundering and terrorist financing

Personal liability An officer of the business who is knowingly concerned in a breach of the Regulations may be subject to a civil penalty. They may also be committing a crime if they do not meet the Regulations. This may result in an unlimited fine and either a prison term or both, of up to 2 years.


This is part 1 of how deep dive into the new money laundering requirements for estate agents. Stay tuned as we cover in the upcoming release, risk assessment, systems and controls, controls, due diligence, and reporting. Please speak with MEMA on how you understand and implement the guidance.