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Additional penalties for AML failures announced

30th July 2018

HMRC have announced they will now levy a Penalty Administration Charge in addition to any penalty imposed for failure to comply with anti-money laundering regulations.

According to HMRC “The charge is for costs of issuing penalties to businesses that do not comply with the Money Laundering Regulations.”*

Implemented on 25th July 2018, a penalty of up to £1500 will be levied for failures to comply with:

  • customer due diligence
  • client risk assessment
  • money laundering policies, controls and procedures
  • record keeping

And up to £350 for breaches such as:

  • failing to register with HMRC
  • failing to tell HMRC of changes to your business
  • failing to provide information

The fines reveal much about HMRC’s focus when it comes to compliance.

It is not just the physical client checks that HMRC are looking for. It is easy to get hung up on getting hold of photo ID, or utility bills.

Agents must challenge themselves to better understand what risk is posed; whether that be from the client(s) and/or the nature of the transaction.

The charges indicate the same level of emphasis on the “why” as well as the “how,” making a demonstrable and documented audit trail a critical part of compliance.

The critical element is to; document both the process (in your risk assessments, money laundering policies and procedures) and the actual undertakings; retaining your records for the requisite 5 years after the end of the business relationship.


Read Landmark’s latest blogs “Is a passport enough for AML” for top tips on identifying client and transaction fraud and ensure your estate agency is not falling foul of AML regulation.


Compliance in a Box from Landmark is the estate agent’s AML toolkit, providing a consistent and documented AML process across your business. From one account you can undertake and evidence:

  • verification of buyers and sellers within a minute
  • enhanced due diligence where your risk assessment identifies it is needed
  • confirmation of home owners
  • retained documentation for the requisite 5 years… and more

For more information about undertaking and evidencing your compliance with the Money Laundering Regulations 2017, sign up below or please contact Compliance in a Box on 01524 220013.

Find out more



*Source: Penalties and appeals for money laundering supervision

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