“It is important to note that you, as the EAB, are responsible for ensuring you comply with all of your obligations under the regulations. Any service, product or report the third-party provides must be examined by you, and you need to decide what, if any, further action you need to take to ensure you meet your obligations under the regulations.”
HMRC guidance for estate agency businesses
If you work in estate agency, you’ve probably heard some version of this in the office:
“We’re fine, we’ve got an AML app that does all of that.”
The client scans a passport, the app shows a green tick and the team moves on.
The problem is: HMRC doesn’t see that as “job done”. In their own guidance to estate agency businesses, HMRC is very clear:
Third-party identity and compliance services can help.
But you, as the supervised estate agency business, remain responsible.
Any report or risk score is just input – you still have to decide what else to do.
And there's the rub: 'what else to do' is quite a lot. ID verification is a slice of AML, but unfortunately only quite a thin slice. It still leaves a lot of risk and complexity with the estate agent, which means a lot of work which if it isn’t done, means you’re not compliant at all.
So what else is required, and how do you get it done?
Most of the tools in the market do some combination of:
identity document checks
basic database look-ups
simple sanctions and PEP screening
a coloured “risk score” or tick/cross.
These are all helpful, but to be compliant, the AML for an estate agency business also needs to include:
understanding your business-wide risks
setting clear policies and controls
risk-rating clients and transactions, not just documents
digging properly into Source of Funds and Source of Wealth
watching for giftors and third-party funders
having a suspicious activity reporting process that properly works
training your people and testing that they follow the process
and keeping records and MI that would satisfy a real inspection.
That’s why HMRC provides a warning to estate agents: a report from an ID app should not be confused with a compliant AML framework.
So what does a fully compliant AML framework for an estate agent look like?
There are hundreds of pages of compliance legislation and guidelines from multiple sources out there, and estate agents would be forgiven for not knowing quite where to start. It is hard to know where those ID checks fit in, let alone what else needs to happen around them.
We thought it was high time that estate agents - and the conveyancers they work with - had one clear AML framework that would show them exactly what is required. So we created The Coadjute Assured Compliance AML Framework, with our three-layers that put it all together.
In our framework, we draw the whole universe of AML requirements as a simple three-layer wheel:
Let’s look at what each of these involves.
The outer circle is the regulatory world:
It’s the same basic world for estate agents, conveyancers, lenders, and everyone else in the property chain. You can’t rewrite this circle. But you can decide how you respond to it.
The middle circle is where AML stops being abstract law and becomes how your business is run.
We boil it down to eight practice-level foundations:
Those eight foundations are what HMRC will look for when they assess how seriously you take AML. They want to see not just that you’ve bought an app, but that you connect these elements to what actually happens on an individual file.
The inner circle is where AML becomes day-to-day work. Every regulated property case needs to pass through the same five steps:
If you use Coadjute, we deliver the entire inner workflow for you. This means that your staff don’t just have a PDF of a policy they are supposed to follow, they have a guided process built into their daily tools, backed up with a comprehensive, fully compliant service.
The Digital ID checks are still there. But now they’re in their proper place as part of step one, not the whole show. Our framework is designed to do three things for estate agents:
Make HMRC’s warning practical: Instead of saying “you are responsible, good luck”, we give you a model that shows what that responsibility actually looks like across your business and on each case.
Turn ID and compliance tools into inputs, not crutches: An ID app is a valuable fact finding tool. We plug it into the inner workflow and wrap it with risk assessment, SoF/SoW, approvals and SAR decisions.
Align you with your conveyancers: Conveyancers are subject to the same Regulations and similar risk themes. Because the framework is designed for both sides, you can share a common view of risk on a transaction instead of starting again from scratch.
We also provide the templates and support you need for the middle circle, so you have a fully compliant service.
The end result? Fewer “we thought the app covered that” moments. Fewer awkward questions from supervisors. Less duplicated effort for clients. Plus, a totally clear answer when the HMRC auditor asks: “How do you manage AML here?”.
It’s easy: “We follow the Coadjute Assured Compliance Framework”.
Third-party ID providers can be a useful part of the solution. But HMRC’s guidance is clear: a basic ID, background or sanctions report is only ever a small part of what is required.
The Coadjute Assured Compliance AML Framework is our way of giving estate agents, and their conveyancing partners, a view of the whole picture:
If you’d like to learn more and walk through how it would look for your agency, we’d be happy to show you. Because AML isn’t a tick in an app. It’s how your whole business chooses to respond to the demands of today's challenging compliance environment.
Book a Demo with Coadjute Today