Are you AML compliant?

Could you evidence your compliance to HMRC tomorrow?

Take our self-assessment to score your business against 15 questions drawn directly from HMRC’s anti-money laundering guidance for estate agents

Start the check

0 of 15 answered

Yes = in place and evidenced · Partly = in progress or informal

  1. Your firm · 1 of 15 Do you have a written, firm-specific risk assessment covering money laundering, terrorist financing and proliferation financing, reviewed in the last 12 months?
  2. Your firm · 2 of 15 Has your risk assessment been updated for your latest changes, such as a new branch, a new service or new technology?
  3. Your firm · 3 of 15 Are your policies, controls and procedures approved by senior management, with names and dates recorded?
  4. Your firm · 4 of 15 Have your policies been shared with every colleague in the last year, and can you prove it?
  5. Your customers · 5 of 15 Do you verify both the seller and the buyer before the relationship begins: the seller before marketing, the buyer before the sale is binding?
  6. Your customers · 6 of 15 Do you scrutinise the source of funds on every purchase, not just the high-risk ones?
  7. Your customers · 7 of 15 When a deposit includes a gift, do you check the giftor and where their money came from?
  8. Your customers · 8 of 15 For company or trust customers, do you identify and verify the beneficial owners, beyond the Companies House register?
  9. Higher risk · 9 of 15 Do you screen every customer for PEPs and sanctions, and get senior-management approval before proceeding with a PEP?
  10. Higher risk · 10 of 15 Do you have a written enhanced due diligence approach for higher-risk cases?
  11. Your people · 11 of 15 Has every relevant colleague been trained in the last 12 months, with records of what, when and how well they understood it?
  12. Your people · 12 of 15 Does everyone know who your Nominated Officer is and how to report a suspicion, without tipping off?
  13. Your records · 13 of 15 Do you record why a suspicion was, or wasn’t, reported?
  14. Your records · 14 of 15 Could you produce, tomorrow, the full evidence for any sale in the last five years?
  15. Your records · 15 of 15 Do you examine what your ID or compliance provider gives you, rather than just accepting a pass or fail?

This self-assessment is designed to help you think about your obligations.  Please note it isn’t legal advice or a complete assessment of your compliance.  HMRC’s guidance and your own legal advice apply.