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26th June 2017: 4MLD comes into law

26th June 2017

The latest update to the Money Laundering Regulations 2007 came into effect from the 26th June.

We are however still awaiting final clarification from HMRC on what exactly the implications of the change, known as the 4th Money Laundering Directive (4MLD), will be for estate agents.

A final private consultation was circulated recently with responses requested by 28th June. HMRC has also released its interim guidance which outlines much of what previous consultations have suggested.

  • Buyers as well as sellers will become subject to Customer Due Diligence (CDD)
  • UK based Politically Exposed Persons (PEPs) will be required to be identified, and Enhanced Due Diligence (EDD) undertaken (Read more about how to deal with PEPs here)
  • Lettings was not to be included and would remain outside of the legislation


The inclusion of buyers is a significant change with additional administrative and cost implications for agents. Indeed, the cost of new processes and procedures will be largely borne by the agents where a Landmark survey identified that 96% of agents absorbed such additional overhead.

Critically no illegal funds need to have passed through your business in order for you to be culpable. Landmark have long advocated electronic checks as part of your AML processes where in most cases there is no need to collect paper ID and results are returned in under 1 minute. With the inclusion of buyers, electronic checks;

  • enable you to deal with both clients you meet face-to-face and remote clients
  • identify persons on government sanctions lists and Politically Exposed Persons (including UK PEPs, now a requirement under the 4th Money Laundering Directive)
  • demonstrates a consistent approach to AML risk across your business
  • save time on your AML processes



In response to 4MLD, Compliance in a Box from Landmark has launched an enhanced AML pack to help agents carry out and document customer due diligence (CDD) and enhanced due diligence (EDD) on vendors and purchasers. No contracts, tie ins or ongoing fees, simple pay as you go compliance. Contact Samantha Peacock (sam.peacock@landmark.co.uk) today on 01524 220013 or SIGN UP BELOW.

Register for Compliance in a Box today



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