the cost of getting it wrong

Stricter compliance rules every year, by design

Property is a major focus in the UK government’s fight against money laundering. Since 2025, new guidance, regulations and national priorities have raised the bar and tougher requirements and scrutiny are now in place.

Illustration of AML compliance: a large tick badge surrounded by a padlock, a shield with a house, a passport, a person icon and labels reading “Policies”, “39 risks assessed” and “ISO 31000”.
Enforcement is already rising

The numbers are moving in one direction

60%
of the businesses HMRC assessed in 2024-25 were found non-compliant
5×
more formal enforcement actions in a year: from 157 to 798
59
registrations suspended or cancelled in 2024-25, up from none in 2022-23. 20 were estate agencies
6
criminal convictions under the Money Laundering Regulations in 2024-25
Published

673 penalties on estate agents

HMRC named 673 penalties on estate agency businesses between January 2024 and September 2025, worth £3.77 million. The largest was £52,000.

Inspection

32 entries without a warrant

HMRC used its power to enter and inspect premises without a warrant 32 times in 2024-25, where it suspected breaches.

Findings

The work itself

The most frequent failures HMRC found: inadequate policies and procedures, inadequate customer risk assessment and inadequate records.

Sources: HM Treasury, Anti-money laundering and counter-terrorist financing: supervision report 2024-25 (December 2025), figures across all sectors HMRC supervises unless stated; HMRC, Businesses that have not complied with the money laundering regulations (2024 to 2025 and 2025 to 2026 lists, as updated September 2026), estate agency business entries only.

Directors and MLROs can be penalised too

HMRC can penalise or ban directors, partners and other officers who knowingly contribute to a breach, whether by approving, allowing, assisting or turning a blind eye to it. 

  • Officers can be prosecuted too

    Company officers can also face criminal prosecution for breaches involving their consent, connivance or neglect, even if the business becomes insolvent. The 2026 strategy proposes tougher director accountability. 

  • What “knowingly concerned” looks like

    Approving a customer relationship without due diligence or enhanced due diligence. Approving an inadequate risk assessment or policies. Failing to communicate policies to staff. Failing to appoint a nominated officer.

  • Not knowing isn’t a defence

    For a criminal offence, neglect is enough: failing to keep appropriate safeguards in place, even without knowing the facts.

What HMRC can do

HMRC can act in any of nine ways

When a business breaches the Regulations, HMRC can take a range of enforcement actions, individually or together, designed to be proportionate and deter future breaches. 

  1. Civil

    A financial penalty

  2. Public

    Published by name

  3. Public

    A censuring statement

  4. Registration

    Suspension

  5. Registration

    Cancellation

  6. Personal

    A ban on managing

  7. Court

    An injunction

  8. Criminal

    A criminal investigation

  9. Turnover

    Your income, as proceeds of crime

Every year, the bar rises.
And it is now rising faster

Scroll down the years to see how the regulation standards have moved.

  1. 2017

    The Money Laundering Regulations

    The rules estate agents work under today: a firm-wide risk assessment, policies, controls and procedures, due diligence on every customer, training and records.

  2. 2019

    A £215,000 penalty

    HMRC reports a £215,000 penalty on a national estate agency group for breaches of the Money Laundering Regulations.

  3. 2021

    Estate agency risk raised

    After the 2020 National Risk Assessment, HMRC raises the money laundering risk of estate agency services from low to medium.

  4. 2022

    A first criminal conviction

    HMRC secures its first criminal conviction of a person running an estate agency business while unregistered, announces penalties totalling £519,645 on 68 estate agents, and publishes separate risk guidance for estate agents.

  5. Jul 2025

    The National Risk Assessment

    Up to £10 billion a year could be laundered through UK property. The risk through estate agents has slightly risen since 2020.

  6. Sep 2025

    Detailed risk indicators

    HMRC adds risk indicators for estate agency businesses following the National Risk Assessment, with more detailed risk characteristics to address.

  7. Dec 2025

    Enforcement up fivefold

    HMRC’s formal enforcement actions rise from 157 to 798 in a year. 60% of the businesses it assessed are found non-compliant.

  8. Jun 2026

    Amended regulations in force

    Changes to the Money Laundering Regulations take effect on 30 June 2026.

  9. Jul 2026

    A new HMRC manual

    HMRC brings its guidance into a single anti-money laundering manual, with more detailed estate agency guidance and new risks to address.

  10. Sep 2026

    A national strategy

    At least £550 million and more than 500 new officers. In the government’s words: “This Strategy marks a turning point.”

  11. 2026-27

    New enforcement powers (planned)

    The Treasury will consult on unannounced visits and on strengthening supervisors’ ability to hold directors accountable for breaches.

  12. 2027-29

    Years two and three of the strategy (planned)

    Year two: “Intelligence moves faster. Disruption increases.” Prosecution and recovery pipelines are strengthened end to end.

    Year three: “Every part of the system will be operating at a higher level, and the results should be visible.”

The criminal offences

Failure to comply is an offence in itself

To prosecute a breach of the Regulations, the prosecution doesn’t need to prove any money laundering, only that the requirements weren’t followed. Separate offences apply when suspicions aren’t reported, and the test is objective: what you had reasonable grounds to know or suspect.

Breaching the Money Laundering Regulations

What it covers

Failing in a relevant requirement, such as your risk assessment, policies, controls and procedures, customer due diligence or enhanced due diligence

Maximum sentence

2 years in prison, an unlimited fine, or both

Failure to disclose

What it covers

Knowing, suspecting or having reasonable grounds to suspect money laundering in the course of your business, and not reporting it

Maximum sentence

5 years in prison

Tipping off

What it covers

Disclosing information likely to prejudice an investigation

Maximum sentence

2 years in prison, a fine, or both

Money laundering

What it covers

For example, becoming concerned in an arrangement you know or suspect helps someone acquire, keep or use criminal property

Maximum sentence

14 years in prison, a fine, or both

Find out where you stand

Book a free 30-minute AML health check. We’ll map your agency against what HMRC expects and show you exactly what we’d take on.