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      Who has to do anti-money-laundering checks - estate agents, letting agents or landlords?

      In England and across the UK, anti-money-laundering duties fall mainly on estate agents and on letting agents dealing with high-rent lets, while the sanctions-reporting regime for letting agents is now wider than AML due diligence. The key split is between MLR 2017 customer due diligence, the £10,000-a-month letting threshold, and OFSI financial-sanctions reporting from 14 May 2025.

      By Abodient Team Published 01 September 2026 8 min read
      Who has to do anti-money-laundering checks - estate agents, letting agents or landlords?

      In England and across the UK, anti-money-laundering duties fall mainly on estate agents and on letting agents dealing with high-rent lets, while the sanctions-reporting regime for letting agents is now wider than AML due diligence. The key split is between MLR 2017 customer due diligence, the £10,000-a-month letting threshold, and OFSI financial-sanctions reporting from 14 May 2025.

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        Do estate agents have to do anti-money-laundering checks on buyers as well as sellers?

        Yes: UK estate agents have to do anti-money-laundering customer due diligence on buyers as well as sellers once the seller accepts the buyer’s offer. Regulation 4 of the Money Laundering Regulations says, “For the purposes of these Regulations, an estate agent is to be treated as entering into a business relationship with a purchaser (as well as with a seller), at the point when the purchaser's offer is accepted by the seller.” HMRC’s AML guidance says the customer for an estate agent “will be both the buyer(s) and the seller(s) of a property,” so AML checks for estate agents UK are not seller-only checks. HMRC also says an estate agency business cannot establish the buyer or seller relationship if it has not completed customer due diligence. In practice, estate agents may ask buyers for identity, proof of address and source-of-funds information before the sale progresses, while the buyer’s conveyancer will run its own separate checks.

        Do private landlords have to do AML checks?

        No: a private landlord who owns property in their own name and lets it directly without an agent does not have to do MLR 2017 AML customer due diligence merely because the rent is high. HMRC states, “Private landlords, who own property in their own names, over the threshold and market them to rent themselves, without going through an agent, are not within scope of the regulations as a LAB.” The important exception is a company or business landlord letting directly by way of business: HMRC says, “Commercial landlords (businesses and companies who, by way of business, seek to find tenants for land or property over the threshold) are LABs.” So AML checks for private landlords are not a general duty on ordinary self-managing individual landlords, but a business or company landlord that is effectively carrying on letting agency business above the threshold may have to register and comply. Tenant referencing and sanctions screening sold to landlords are different from MLR customer due diligence.

        Do letting agents have to run money-laundering checks on tenants?

        Letting agents have to run MLR customer due diligence on tenants only for in-scope letting agency work: a let for a month or more where the rent is £10,000 or more per month, and the duty covers due diligence only, not the separate sanctions regime. Regulation 27 says, “The letting agent must apply customer due diligence measures under paragraph (7A) in relation to both the person by whom the land is being let, and the person who is renting the land.” The old public shorthand of 10,000 euros is stale for current law: the 2026 amendment says, “In regulation 13(4)(b)(ii)(1), for ‘10,000 euros’ substitute ‘£10,000’.” Below that rent, HMRC says letting agents should not register and do not need to apply the MLRs if they do not and are unlikely to execute agreements exceeding the threshold. Many agents still check tenants through referencing, but that is not the same as a statutory AML tenant check.

        Do letting agents have to check tenants for sanctions even below the AML rent threshold?

        Yes: since 14 May 2025, UK letting agents are within OFSI financial-sanctions reporting at any rent, so the £10,000-a-month threshold limits full AML due diligence only and does not limit sanctions reporting. OFSI’s letting-agent guidance says, “The reporting obligations will apply in relation to letting agency work irrespective of the value of any rental agreement.” The duty is framed as a reporting duty where the agent knows or has reasonable cause to suspect sanctions involvement: OFSI says a relevant firm must report as soon as practicable if it knows or has reasonable cause to suspect that a person is a designated person or has committed a breach. That is why many agents now screen tenants and landlords against sanctions lists even on ordinary residential rents: it is the practical way to avoid missing a reportable match. The stale €10,000 figure on some AML pages should not be used for this sanctions point.

        At what point in a letting does the duty to check or report start?

        For a prospective tenant, the letting-agent reporting point starts after the landlord accepts the tenant’s offer and before the tenancy agreement is signed. HMRC says, “Your business relationship with a prospective tenant starts at the point at which the tenant’s offer is accepted by the landlord,” and it adds that “You must have completed the ID verification aspects of CDD on the tenant, guarantor or trustee before any agreement or contract is made.” OFSI uses the same practical window for tenant sanctions reporting: it says a letting agent must report in relation to a prospective tenant from the point the landlord and tenant are in the course of concluding an agreement for a letting of land for a month or more. A mere enquiry or viewing does not create the tenant relationship; HMRC says, “Simple requests for information may not result in any further contact or interest and does not form a business relationship.”

        Do the money laundering rules only apply to UK-based clients?

        No: for a UK business within the Money Laundering Regulations, the rules are not limited to UK-based clients, and overseas landlords, buyers, sellers or tenants are not exempt just because they are abroad. Regulation 9 says that, for business carried on in the UK, “it is irrelevant where the person with whom the business is carried on is situated.” For in-scope letting agents, Regulation 27 requires CDD on both “the person by whom the land is being let” and “the person who is renting the land,” with no UK-residence condition. HMRC treats overseas customers as a higher-risk factor, not a carve-out: “Services provided to or from overseas jurisdictions or customers, intermediaries and third parties who are resident, have their principal place of business, or are incorporated overseas may pose an increased risk of money laundering, terrorist financing or proliferation financing.” Financial sanctions also have UK-wide reach, including UK persons wherever they are in the world.

        Last reviewed September 2026.

        Sources

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