Landlord FAQ

1. About the sanctions checks

As of 14 May 2025, letting agents have been classified as “relevant firms” under UK financial sanctions regulations, overseen by the Office of Financial Sanctions Implementation (OFSI). This means:

• Agents must screen landlords against UK and international sanctions lists

• Agents must verify landlord identities and property ownership

• Ongoing monitoring must be conducted to detect any changes

These steps ensure legal compliance.

2. About the check

Q: What documents do I need to provide for the check?
You must submit:

• Valid photo ID (passport or driving licence)

• Proof of ownership (e.g., title deeds, mortgage statement)

• Information about any Ultimate Beneficial Owners (UBOs)

Q: What if my circumstances change after I have successfully completed the check?
It is important that if your circumstances change that you notify us. You must do so if:

• You change your name, contact details, or ID

• You buy/sell property

• Your company or trust ownership structure changes

Q: What if my property is held in a company or trust?
You must disclose and provide information for all Ultimate Beneficial Owners (UBOs), such as company shareholders (25%+), trust beneficiaries, or controlling individuals.

Q: How often does the check need to be completed?

The legislation requires estate agents to apply “ongoing monitoring” to all landlords and tenants, which means staying abreast of any changes to the landlord’s sanctions status. There are two options to comply with this:

1. Perform a check every time there is a new tenant or contractual change between the landlord and the tenant,

2. Check once at a sensible interval and apply ongoing monitoring

We employ method two as it minimises cost and the time required for all parties and provides maximum compliance coverage.

3. Consequences of non-compliance

Q: What happens if I refuse to be screened against the sanctions list?

Both you and your letting agent could face the following consequences:

• Criminal penalties: Up to 7 years in prison and/or unlimited fines

• Civil penalties: Up to £1 million or 50% of the value of the breach

• Daily penalties: For continued breaches and potential public naming

4. Sanctions checks for tenants

Q: Do landlords need to check tenants?
No. The responsibility for checking tenants against sanctions lists lies with the letting agent. Landlords do not have to carry out these checks unless they are managing properties independently without using a letting agent.

5. The process

Q: What is involved in the check?

1. Secure Invitation: You’ll receive an email from Coadjute with a secure link.

2. Document Upload: Submit required documents (takes ~5 minutes).

3. Verification: Coadjute completes identity, sanctions, and ownership checks.

4. Monitoring: Your data is checked on an ongoing basis; alerts are triggered for any matches.

5. Sanctions Reporting: Coadjute registers confirmed matches with OFSI.

6. Fees

Q: What do the fees cover?

Fees cover ID verification, ownership proof, sanctions screening, and daily monitoring for 12 months. Fees are collected annually on the enrolment date and are payable via your letting agent.

Q: Why is the fee annual?

The annual fee relates to the frequency by which we run the check and supports ongoing monitoring. At each renewal we will update the full check which will include ownership, KYC, and then apply sanctions monitoring once more.

7. Timeline & renewal

Q: What are the timelines I should be aware of?

• Initial Completion: Upload your documents within 14 days of receiving your Coadjute invitation.

• Renewal Reminder: You will be notified one month before your annual renewal date.

• Annual Renewal: Fees and checks renew automatically each year; re-verification may be required if details change.

8. Data privacy & security

Coadjute takes privacy very seriously. We ensure:

• Secure Uploads: All documents are transmitted over encrypted, secure channels.

• Restricted Use: All personal data is used solely for compliance and monitoring.

• Retention: We retain records only as long as legally required.

9. About Coadjute

Q: Who is Coadjute?
Coadjute is our compliance partner providing:

• Government-approved identity verification
• Sanctions and ownership screening
• Ongoing monitoring and OFSI reporting

Backed by Rightmove, Lloyds, Nationwide, and NatWest, Coadjute is committed to the highest standards.

Q: Is Coadjute regulated?
While compliance providers are not individually licensed by the government, Coadjute operates under the oversight of the Information Commissioner’s Office (ICO) and complies with all relevant OFSI and FCA standards.

Q: Does Coadjute’s Assured Compliance service cover lettings, sales, and purchase?

Yes, Coadjute’s Assured Compliance service covers compliance for lettings, sales, and purchases. The checks we conduct for sales and lettings comply with respective legislation and confirm to HMRC and OFSI standards respectively.

10. What happens if there’s a match?

Q: What if a name matching mine is on the sanctions list?
If there is a potential match:

• The transaction may be paused

• Coadjute will report to OFSI

• OFSI investigates and confirms true or false match

• If confirmed, assets may be frozen and legal measures enforced

11. Types of sanctions checked

We screen against:

• UK and UN financial sanctions

• Trade and investment restrictions

• Transport sanctions (e.g., sanctioned ships or aircraft)

These checks ensure no rental income benefits a sanctioned party.

12. AML vs. sanctions checks

Q: Is this the same as Anti-Money Laundering (AML) checks?
No. Sanctions compliance is separate from AML. Even if you’ve passed AML checks, you must still complete OFSI screening.

13. Compliance reports for other agents

Q: Can I use my report with another letting agent?
Yes. Once verified, you will receive a compliance report via Coadjute’s secure portal. You can download and share it with other agents. Acceptance is at their discretion.