Property Market: Four possible new models for an AML supervision

Four possible new models for an AML supervision
Written by Malcolm Driscoll MA AICA Int. Adv. Cert (AML), Lead AML Consultant, FCS Compliance – Property Division


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The Treasury is currently looking at four possible new models for AML supervision and, while this is still at a consultancy stage, we at FCS Compliance are mindful of any impact this could have on our clients and the property industry.

In brief: – Estate and letting agents currently fall under the remit of HMRC for AML purposes but other professionals they work with such as conveyancers may be supervised differently such as through their professional bodies. The Treasury has proposed the creation of a Single Professional Services Supervisor (SPSS) in the legal and accountancy sectors, which could include estate and letting agents.

The Treasury consultation says:

“The inclusion of estate agents in the scope of an SPSS could lead to increased supervisory effectiveness, particularly through improving system coordination. Currently, conveyancing professionals are supervised by legal professional body supervisors and would fall within the remit of an SPSS. There could be opportunities for improvements in understanding of risk in the real estate sector through placing conveyancing professionals and agents under a single supervisor. This should allow a better appreciation of trends and risks in the property market, and improved identification of breaches.”

FCS is monitoring this proposal closely and will provide any updates or changes to the current structure of supervision.

Article written September 2023.