AML compliance
What does HMRC’s new guidance require of UK estate agents?
UK estate agents must check who buyers and sellers are, confirm where their money comes from and report anything suspicious. APLYiD explains what HMRC’s AMLG2200 guidance means in practice.
At a glance
Estate agents must run checks: identity, source of funds, source of wealth where required, and suspicious activity reporting all sit within the AML process.
The scope is broad: high street agents, online-only agents, property sourcers, deal packagers, auctioneers and investment brokers can all be covered.
Timing matters: seller checks, buyer checks, auction checks and sourcing checks all have different trigger points.
APLYiD helps automate the process: identity checks, biometric verification, screening and audit trails can be managed in one guided workflow.
UK estate agents must check who their buyers and sellers are, confirm where their money comes from and report anything suspicious.
This comes from HMRC’s AMLG2200 guidance for Estate Agent Businesses, issued under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017.
The scope is wide. If a business buys, sells, markets or sources UK property, it is likely covered, including online-only agents, property sourcers and auctioneers.
The good news is that none of this needs to slow a sale down. Done well, AML checks can happen early, cleanly and without derailing the transaction.
APLYiD automates identity, source of funds and screening checks, helping agents get compliance completed in minutes rather than days and keeping deals on track.
What is AMLG2200 and who has to follow it?
AMLG2200 is HMRC’s Anti Money Laundering guidance for Estate Agent Businesses, sitting under MLR 2017.
HMRC supervises Estate Agent Businesses directly, so estate agents register with HMRC rather than a separate property body.
The guidance covers any firm or sole trader doing estate agency work, as defined in the Estate Agents Act 1979. HMRC is clear that online-only businesses with no physical premises are still in scope.
Property sourcing platforms, deal packagers and investment brokers receive the same treatment as high street agents.
What counts as estate agency work under UK law?
The definition covers far more than the final sale.
It includes buying or selling freehold or leasehold property, including commercial and agricultural property, sending property details, arranging viewings, advising a buyer or seller, and acting as an intermediary between the two.
Estate agency work can also include:
- “For sale” boards
- Property sourcing
- Deal packaging
- Investment brokering
- Buying property for resale
- Selling developer-owned property
- Auctioneering
- Relocation services
- Competitions where the prize is a property
Any business doing this needs to register with HMRC and run due diligence.
A shorter list sits outside the rules, including private sales with no third party, pure advertising, platforms that connect buyer and seller with no advice given, solicitor-led conveyancing in England and Wales, Scottish solicitors’ property centres, independent property management, planning work, activity entirely outside the UK, mortgage arranging and Scottish home reports.
The important bit?
If you are involved in the buying, selling, marketing or sourcing of UK property, do not assume you are outside the guidance.
When does customer due diligence need to happen?
Once a business is an estate agency business, it must identify and verify every party to a transaction under Regulation 28 and Regulation 30 of MLR 2017.
Verification has to happen before the business relationship starts, and HMRC recommends starting checks from first contact rather than leaving them until the end.
This also applies to existing customers unless they have already been verified properly.
A few common scenarios:
- For shared ownership properties, every owner needs checking, not just the lead name.
- If someone acts on a customer’s behalf, such as a solicitor or buying agent, the estate agent needs to identify and verify them too.
- If that representative is an Estate Agent Business, the agent also needs to confirm their HMRC registration.
- Agents can rely on another regulated business’s checks through a formal reliance agreement.
Exactly when does an offer trigger the identity check?
Timing depends on who is being checked, and it is one of the most missed parts of the guidance.
Buyer: checks need to be done by exchange of contracts.
Seller: checks need to be done before marketing starts, when they sign with the agent.
Property sourcing customer: checks are due at the point of instruction.
Auctioneer: seller checks are due at the listing agreement, and buyer checks are due before the contract becomes binding.
Knowing these dates upfront means checks stay ahead of the deal rather than chasing it later.
What extra checks apply to cash buyers or unusual funding?
Higher-risk deals need enhanced due diligence, covering both source of wealth and source of funds.
Source of wealth looks at how someone built their money overall. Source of funds looks at where the specific payment for this transaction is coming from.
HMRC suggests agents ask:
- Has the funding source changed mid-transaction?
- Does the amount match the customer’s known income?
- Can the agent show their reasoning for proceeding?
Cash buyers are called out specifically as higher risk.
HMRC’s National Risk Assessment 2025 rates money laundering risk in UK real estate as medium, and terrorist financing risk as low. Estate agencies also need to weigh proliferation financing risk, with HMRC flagging higher risk on transactions linked to countries including North Korea and Iran.
What happens if an estate agent cannot complete the required checks?
If an estate agent cannot complete the required checks, it cannot process the transaction through the customer’s bank account, start a relationship with them another way or continue an existing relationship where checks are incomplete.
The agent also needs to consider whether a Suspicious Activity Report is required.
Run the checks early, and AML stays a background step. Leave it late, and it can become a transaction blocker.
What are an estate agent’s suspicious activity reporting duties?
Every estate agent has its own legal duty to file a Suspicious Activity Report when it suspects money laundering or terrorist financing, whether or not the deal goes ahead.
HMRC is clear that agents should not assume someone else on the deal, such as a solicitor or bank, will report it instead.
Multiple reports on one transaction are fine. Nobody reporting is not.
The duty also covers the whole business, so a concern raised by a property management arm still counts.
How long must an estate agent keep AML records?
Records need to be kept for five years after the business relationship ends, then deleted.
A property transaction counts as a business relationship from first instruction through to completion, withdrawal or cancellation. The five-year clock starts from there.
Registration also depends on business structure. Beneficial owners, officers and relevant managers go through HMRC approval, and a business can start trading once its application is in.
Branches and franchises need attention too:
- Any new branch needs notifying within 30 days of opening.
- If a principal firm controls an agent’s activities and financial crime controls, the principal registers the agent’s premises and owns their compliance.
- A franchisee with genuine operational independence registers separately, directly with HMRC.
How does APLYiD help estate agents meet the guidance?
APLYiD replaces the manual chase for passports and supporting documents with one guided process.
Buyers and sellers submit their documents, biometric checks confirm who they are, and Politically Exposed Person and sanctions screening run automatically in the background.
That extends into the enhanced due diligence HMRC expects for cash buyers and higher-risk deals.
94%
biometric check success rate.
Under 90 seconds
for biometric verification.
70%
reduction in compliance paperwork for agencies using APLYiD.
Everything sits in one dashboard, giving the agency a live view of every client’s compliance status.
Decisions on source of funds and source of wealth can be made and documented as the deal moves, rather than pieced together afterwards.
Checks keep running for the life of the transaction, with automated alerts on anything that changes.
APLYiD helps estate agents:
- Automate identity checks
- Run biometric verification
- Screen for PEPs and sanctions
- Document source of funds and source of wealth decisions
- Maintain a clean audit trail
- Reduce manual compliance paperwork
APLYiD is ISO 27001 certified, self-serve, and comes with a free trial and real human support when needed.
AML made faster
Meet HMRC guidance without slowing the transaction
APLYiD helps estate agents complete identity, source of funds and screening checks in one guided process, with the documentation and audit trail needed if HMRC or a SAR investigation comes calling.
Read the APLYiD guide Explore APLYiD
Automated checks, live compliance visibility and a clean audit trail, all in one dashboard.
