What you need to do

The reality of what is required

HMRC has published extensive guidance for what estate agents need to do at every moment of a sale, for every customer, across your whole firm.  Here are the key points… in plain English.

The lifecycle of every transaction

Six stages with one continuous obligation

Choose a stage to see what HMRC expects, in plain English, with HMRC’s own words where we quote them, and what Coadjute does for you.

Your firm’s AML framework comes first

What HMRC expects

  • A written, firm-specific risk assessment of money laundering, terrorist financing and proliferation financing risk, reviewed at least annually and whenever the business changes
  • Policies, controls and procedures approved by senior management, shared with every colleague and re-shared whenever they change
  • A Nominated Officer appointed and HMRC told of the appointment within the time the Regulations set; every relevant colleague trained

What Coadjute does

  • Your risk assessment built digitally on the platform, from the Coadjute AML Standards Library
  • A customisable policy library, with controls, procedures and evidence standards linked to every check
  • Training assigned by role and recorded in the Training Hub

What stays with you

The decisions only your firm can make, with the evidence in front of you.

In HMRC’s words

A template is fine, but it “must be fully adapted”

Source
HMRC AMLG1800

The seller is your customer from the moment terms of business are signed

What HMRC expects

  • The seller must be verified when they sign your terms, before the property is marketed: name, photo, date of birth and address, with documents checked for genuineness
  • For companies and trusts, identify and verify the beneficial owners: the Companies House register alone isn’t enough
  • Digital identity services should be certified and on the government’s register
  • Check the authority of anyone acting for the seller, such as an executor or attorney

What Coadjute does

  • Guided digital ID from a government-certified digital identity provider, with face matching and liveness checks, or Agent Assisted when a seller needs help
  • Company, officer and beneficial-owner checks; title and ownership checks with HM Land Registry and Registers of Scotland
  • Specialist review of every result, recorded in the AML report

What stays with you

The decisions only your firm can make, with the evidence in front of you.

In HMRC’s words

Every sale is a business relationship with the seller and the buyer

Source
HMRC AMLG2200 (summary)

Now the buyer is your customer too

What HMRC expects

  • The buyer becomes your customer at the point their offer is accepted; verification is expected then, and must be complete before contracts are exchanged
  • Source of funds “must always be scrutinised” on a purchase. Knowing it came from a UK bank account is not enough
  • Gifted deposits: check the giftor and also where their money came from

What Coadjute does

  • Buyer, joint-buyer and giftor checks, with live source-of-funds declarations and chained gifts recorded as they happened
  • Specialists trace the money, request the right evidence and follow up until the picture is complete

What stays with you

The decisions only your firm can make, with the evidence in front of you.

In HMRC’s words

Source of funds “must always be scrutinised”

Source
HMRC AMLG3200

Keep watching until completion

What HMRC expects

  • Monitor the relationship throughout: keep information current and act on changes such as new funding or new parties
  • If something looks wrong, report internally; your Nominated Officer decides whether to make a SAR and seek a DAML before proceeding
  • Never tip off the customer, and never assume another firm will report

What Coadjute does

  • Ongoing monitoring and re-screening throughout the relationship (at least 12 months), red-flag escalation and a clear outcome on every case: Proceed; Consider, for your MLRO’s review; or Stop, where the relationship ends, with a SAR and any DAML prepared where there is suspicion
  • SAR preparation and DAML support for your Nominated Officer

What stays with you

The decisions only your firm can make, with the evidence in front of you.

In HMRC’s words

Never assume “another entity is going to make a SAR”

Source
HMRC AMLG2200

Close the case with a complete record

What HMRC expects

  • Keep the evidence and enough information to reconstruct the transaction
  • Check that the fee is paid by the customer you verified

What Coadjute does

  • A structured AML report for every customer: checks, evidence, risk decisions, mitigations and history

What stays with you

The decisions only your firm can make, with the evidence in front of you.

In HMRC’s words

Records must allow you to reconstruct the transaction

Source
HMRC AMLG11700

Be able to evidence it all, years later

What HMRC expects

  • Keep records for five years after the relationship ends, then delete personal data unless an exception applies
  • Produce your risk assessment, its previous versions, your policies and your training records on request

What Coadjute does

  • Every case, framework version and training record retrievable in one place
  • Coming soon for MLROs: Compliance Insights, showing your firm’s risk profile from its own checks

What stays with you

The decisions only your firm can make, with the evidence in front of you.

In HMRC’s words

Provide records “to HMRC on request”

Source
HMRC AMLG11030
When HMRC expects you to go further

Higher risk means enhanced due diligence

Mandatory

Politically exposed persons

PEPs, their family and close associates need enhanced checks and senior-management approval before the relationship begins. Foreign PEPs are treated as higher risk.

Mandatory

High-risk countries

Any link to a FATF “call for action” country (currently North Korea, Iran and Myanmar) means enhanced checks before the relationship starts.

Mandatory

Unusually complex or large

Transactions that are unusually complex, unusually large or follow an unusual pattern with no apparent legal or economic purpose.

Treat as high risk

Super-prime

£5m or more in London and the South East, or £1m or more elsewhere in the UK.

Higher risk

Property funds and trusts

REITs and OEICs are higher risk; trusts should be treated the same way, with beneficial owners identified.

Higher risk

Citizenship by investment

HMRC expects customers holding a passport from a country that offers citizenship by investment to be treated as higher risk, particularly where they were born elsewhere.

The risks we check against

The Coadjute AML risk library

Coadjute covers all the risks HMRC’s guidance describes under customer, transaction, geography, service and delivery-channel risks, plus the new risks HMRC added in July 2026. 

Customer risks

10 risks
  • Customer profile not in line with transaction
  • Customer behaviour (secretive or evasive)
  • PEPs, family and close associates
  • Corporate structure not wholly UK-based
  • Trust customers
  • REIT / OEIC
  • Cash-intensive businesses
  • Joint ventures and reliance agreements
  • Customers linked to governments of PF-sanctioned regimes
  • Customers sanctioned by the UK for terrorist activity

Transaction risks

14 risks
  • Super-prime property
  • Multiple property transactions
  • Price not reflective of market value
  • Complex or unusual corporate structure
  • Non-transparent legal entity
  • Potential professional enablers
  • No commercial purpose
  • Payment and source-of-funds risks
  • Bridging finance
  • Multiple connected companies / common UBOs
  • Proof of ownership
  • Identifying co-owners
  • Property used to manufacture dual-use goods
  • Linked to PF-sanctioned regimes

Geography risks

4 risks
  • High-risk third countries (HRTC)
  • Overseas (non-HRTC)
  • Intermediaries
  • Virtual office locations

Service risks

4 risks
  • Multiple services on the same asset
  • Payments for estate agency services
  • Offshore ownership or intermediary
  • Property auctions

Delivery channel risks

2 risks
  • No face-to-face contact
  • Third-party ID or compliance providers

New risks

5 risks
  • Organised immigration crime
  • Citizenship by investment
  • Northern Ireland-related terrorism
  • Terrorism and serious organised crime
  • Foreign policy sanctions, including proliferation financing

Risk categories are Coadjute’s own, built on HMRC’s guidance; they are not a count of HMRC’s risk indicators. Your firm’s risk assessment sets which apply to you and how.

Your AML compliance taken care of in full

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Myths and facts

What many agents believe, and what HMRC actually says

Myth

“We use an ID app, so we’re compliant.”

What HMRC actually says

Identity is one part. The Regulations also expect source of funds to be considered on every purchase and scrutinised where the risk requires (regulation 28(11); HMRC’s sector assessment says it “must always be scrutinised”), plus beneficial owners, enhanced checks, a firm risk assessment, policies, training and records.

Myth

“Our provider does the checks, so it’s their responsibility.”

What HMRC actually says

Using a third party “does not absolve you”. You must be able to examine what they provide.

Myth

“Source of funds is only for high-risk buyers.”

What HMRC actually says

The Regulations require source of funds to be considered on every purchase and scrutinised where the risk requires (regulation 28(11)); HMRC’s sector assessment goes further and says it “must always be scrutinised”, and a UK bank account alone is not enough.

Myth

“The buyer’s solicitor checks the buyer.”

What HMRC actually says

The buyer is your customer too. Each firm does its own checks, and should never assume another will report a suspicion.

Myth

“We did our risk assessment when we registered.”

What HMRC actually says

It must be reviewed at least annually and whenever the business changes, with previous versions kept.

Myth

“A template policy will do.”

What HMRC actually says

Templates are allowed, but they must be fully adapted and approved by your senior management.

Myth

“Our staff read the manual.”

What HMRC actually says

Training is needed at the start and regularly after (most firms will need to do it annually), and manuals alone are generally not enough.

Myth

“We’re too small for HMRC to look at us.”

What HMRC actually says

The obligations apply to every estate agency business, and HMRC can ask for your records at any time.

AML compliance is our speciality. Let us show you how

Book a free 30-minute AML health check. We’ll map your agency against what HMRC expects and advise you exactly how compliant your current processes are.