- March 26, 2025
- Posted by: FCS Compliance
- Category: News, Property Market
Remaining compliant as a property professional in the UK has never been more important. From 14 May 2025, new financial sanctions regulations will take effect, placing stricter obligations on letting agents. These changes mean that letting agents must ensure that neither tenants, nor landlords, are listed on government sanctions lists.
The penalties for failing to conduct these checks are severe, ranging from substantial fines to imprisonment for up to seven years.
With these changes on the horizon, we have been inundated with questions via our AML hotline and during our training courses. To help support you we have pulled together the most frequent questions agents have been asking us and answered them in this article.
Where can I find the OFSI consolidated list?
The OFSI sanctions lists can be found here. There is also an OFSI sanctions search function which can be accessed here.
How often is the OFSI sanctions list updated?
There is no fixed schedule for updates to the OFSI consolidated list. It is updated whenever there are new designations or delistings. There may be multiple changes in a week, while at other times, the list could remain unchanged for a month. It’s down to you to check in regularly to see what changes have been made.
When do I need to carry out sanctions checks on tenants and guarantors?
Once an offer has been made and accepted, sanction checks must be performed on all parties involved in the transaction.
When do I need to carry out sanctions checks on landlords or other parties such as owners?
These checks should be made before a property is marketed and prior to a tenant being found. It is also important to consider other parties such as owners if they are in fact not the landlord.
Do letting professionals need to maintain proof of sanctions checks? And what serves as proof?
Whenever you carry out checks or due diligence it is essential to keep records and evidence of your process. If you are performing searches of the OFSI sanction list, take screenshots of the results. If you are investigated, being able to provide this evidence can help strengthen your case.
Do self managing landlords need to check tenants and guarantors?
The simple answer to this is no.
What type of lettings are subject to the OFSI sanction checks?
All lettings agents, dealing with all types of lettings. This includes residential, commercial and land. If you are an estate agency business and renting something, you need to carry out checks.
How do we respond to a tenant or a landlord found on the sanction list?
It depends where you are in the process, but you cannot continue with the transaction unless you receive a license to do so. While the likelihood of receiving a license is low, if you wish to pursue one, the best course of action is to delay until you receive a decision. If you don’t wish to pursue a license you must inform the party that you can no longer proceed with the transaction.
Is the client informed if I submit an OFSI report about them?
The short answer is no. If you make a report, the individual will not be told that you have reported them. Additionally, if an investigation is launched, the agency conducting it will not disclose how they became aware of the potential breach.
Have more questions about the OFSI changes for letting agents?
These changes will significantly impact how letting agents remain compliant. We appreciate that you may have further questions on this topic. If you’re an FCS subscriber you will have access to [ which gives you access to] our AML Hotline, where experienced, industry-specific compliance professionals are just a phone call away to answer any queries you may have.
Upcoming Webinar
We are also hosting a webinar specifically on this topic, which will take place on 10 April at 10am and will discuss the practical implications of these changes for letting agents. You’ll be able to ask any questions you may still have on the topic. Heres what we will be covering:
- How to prepare for the new sanctions obligations in lettings, including the checks involved and the reporting requirements
- What agents must now report to OFSI
- Upcoming changes to Companies House
- The latest updates from HMRC in relation to fines
- A reminder of the latest HMRC standards and how to stay compliant
You can register for the free webinar here. Look forward to seeing you.
