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NCA figures show estate agents still under AML scrutiny

6th February 2018

The National Crime Agency has released figures identifying the number of Suspicious Activity Reports it has received from October 2015 to March 2017.

Previously released figures showed just 355 SARS were submitted by estate agents against the backdrop of 1.2m transactions.

In response to greater scrutiny from HMRC that figure has nearly doubled in the following 12 months and now represents 0.12% of all SARS submitted to the National Crime Agency.

Despite acknowledging that estate agents do not typically handle funds, in its guidance HMRC is clear about why the sector is under scrutiny:

they are a key facilitator in a property sale and come into contact with both parties to the transaction at an early stage and so are in an ideal position to identify suspicious activity[1]

Since June 2017 estate agents have been required to undertake checks on purchasers as well as sellers before entering into a business relationship. The guidance here is clear; a seller must be checked prior to the property being listed. Purchasers must be checked prior to exchange, although many agents are now undertaking such checks at the point the offer is accepted, either informally or formally.

Such checks, known as Customer and Enhanced Due Diligence, form part of a process known as Know Your Customer (KYC) which encourages you to look at the transaction in the round and identify if there are any red flags, both in terms of the individual(s) you are dealing with and the transaction.

You should have a demonstrable audit trail and a risk assessment that details how and why you came to your conclusion in the initial stages of the business relationship. If something changes down the line you can reassess that decision and ultimately refuse to act on their behalf.


Compliance in a Box from Landmark helps agents streamline the compliance process into a few clicks from one place;

  • Electronic AML checks to apply CDD
  • Identify PEPs and those on sanctions lists
  • Foreign national checks for non-UK based clients
  • Land Registry title information to verify property ownership
  • Company checks to identify beneficial owners
  • Retained copies of all documentation with time & date-stamped audit trail for MLRO

Make sure you fully understand your transactions, mitigate your AML risk, and save your business time, with Compliance in a Box. Sign up below to register for your Landmark account, or contact Samantha Peacock on 01524 220013 / sam.peacock@landmark.co.uk

Register for more information




[1] 4.2 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/628696/Estate_Agency_Businesses_Guidance_.pdf

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