2024 AML Recap for the Property Market

2024 Case Studies

2024 was a year in which we continued to see regular reports of money laundering cases involving the purchase of property in the real estate market. The scope of this activity has ranged from properties purchased well below ‘super-prime’ (£800,000) to luxurious homes in Kensington (£27M).

These cases highlight the fact that money laundering through the property market remains widespread, and that agents are vulnerable to being exploited to launder illicit funds—especially when compliance failures lead to breaches of the Money Laundering Regulations (MLR 2017).

HMRC 

Increased Scrutiny 

2024 has also seen increased activity from HMRC, the supervisory authority for estate agents. Inspections have continued as the agency seeks to identify businesses that either fail to register for AML—potentially unaware of the risks they face in property transactions—or those that, despite being registered, continue to operate without full awareness of their obligations or the latest guidance, which was last issued by HMRC on 31 January 2024.

Avoiding Scams

HMRC issued guidance on how to avoid being scammed by fake HMRC agents. This guidance included tips on how to identify legitimate communication from HMRC across different mediums such as letters, embed QR codes, texts, phone calls, and WhatsApp messages (if you’re subscribed). More information can be found on the topic here.

FCS Updates

So, what has FCS done for you in 2024, what will we continue to do in 2025, and how have we worked with agents to strengthen AML compliance and reduce the risk of money laundering? Here are just a few key initiatives:

• AML Protect – A free service that ensures you never miss your AML registration renewal by notifying you in advance, helping you avoid the risk of missing HMRC’s renewal email.
• AML Training – Our dedicated team of AML trainers continue to provide courses for both new and experienced professionals in the real estate sector. From foundation-level training to MLRO obligations, we now also offer a practical ‘CDD Workshop’ designed to boost staff confidence and competence in completing CDD.
• HMRC Support and Mock Inspections – With HMRC increasing its oversight, we have helped agents prepare for inspections by auditing files and providing valuable insights into what to expect during the process.
• CDD Support – Assisting agents with complex CDD requirements, particularly when dealing with opaque company or trust structures.
• Changes in Legislation and Guidance – Staying informed is crucial in AML compliance. Through training, consultancy, and newsletters, we have kept agents up to date with the latest regulatory changes.
• Webinars – Our industry-wide webinars, presented in partnership with organisations such as Rightmove (Rightmove members can register for our upcoming webinar for free), have provided critical insights into compliance measures and HMRC’s supervisory approach. Due to exceptional demand, these will continue in 2025.

Looking Ahead

As we move into 2025, AML compliance remains a priority for estate agents, read Top 5 critical AML watch-outs for 2025. With HMRC’s heightened scrutiny and evolving regulations, staying proactive is essential to safeguarding your business. FCS remains committed to providing expert support, training, and resources to ensure you remain compliant, confident, and ahead of the curve.

If you have any questions about AML compliance or would like to learn more about our services, get in touch with the FCS team today.