- May 28, 2025
- Posted by: FCS Compliance
- Category: Blog, Property Market
Recent research from Transparency International UK has laid bare the scale of dirty money flowing into British property. The report revealed that since 2016 over £11 billion of suspicious wealth has been linked to UK real estate. The organisation investigated 78 cases of corruption linked to African nations, drawing on court records, leaked documents, and publicly available data. The UK ranked among the top 10 countries used for laundering these corrupt proceeds – with property transactions playing a central role. It’s a clear signal that overseas criminals continue to see UK real estate as a safe haven to conceal their assets.
For those of us working in the sector, this reinforces the critical importance of rigorous Anti-Money Laundering (AML) practices. Customer Due Diligence (CDD) isn’t just a legal obligation – it’s a frontline defence against exploitation by such criminals.
By combining Transparency International’s revelations with our practical knowledge of UK regulation and enforcement, we highlight the risks and realities faced by UK real estate professionals.
How does the money flow in?
Transparency International’s (TI – UK) recent analysis identified over £11 billion of suspicious wealth linked to UK properties since 2016¹. More than half of this (£5.9bn) was hidden in offshore shell companies registered in Britain’s Overseas Territories[1]. Notably, over 90% of those suspect funds came through the British Virgin Islands (BVI)[2]. These arrangements are a known red flag for money laundering and are often the vehicle of choice behind which a beneficial owner can hide.
According to TI-UK’s findings, nearly three-quarters of the high-risk properties they identified are held via companies incorporated in secrecy jurisdictions – including the British Virgin Islands, Jersey, and the Isle of Man.
Such jurisdictions do not require public disclosure of beneficial ownership, making them ideal vehicles for laundering illicit funds. Wealth can be layered through multiple trusts or companies, often across several countries, to obscure its origin before being invested into UK property.
These structures are then used to acquire high-value real estate – particularly in prime central London, where properties are both prestigious and easily resold.
Why the UK property market?
TI-UK and others have long pointed to the UK’s combination of high property values, and global reputation as one that makes it especially attractive to money launderers.
For years, individuals seeking to hide illicit wealth have taken advantage of the UK’s previous lack of transparency around property ownership.
Despite the introduction of the Register of Overseas Entities (ROE) – requiring foreign companies holding UK land to declare beneficial ownership – many entries have missing, unverifiable, or clearly false data. According to TI-UK, over half of the foreign companies on the register may still be non-compliant, and no penalties have yet been issued by Companies House as of early 2024.¹ This isn’t just a domestic issue; it’s a global one. Examples include international corrupt PEPs (Politically Exposed Persons) from Angola using offshore vehicles to siphon public funds ending up in the purchase of UK property.
What does this mean for compliance professionals and estate agency businesses?
For estate agents, solicitors and developers, the message is clear: don’t assume a transaction is risk-free simply because it looks polished on the surface.
Now more than ever, firms must take a holistic view of their AML compliance frameworks — not just ticking boxes, but actively assessing how well their systems hold up under real scrutiny. This includes reviewing how risks are identified, documented and responded to across the business.
An independent AML audit or compliance health check can provide critical insights, revealing blind spots in processes and ensuring that firms are fully equipped to deal with complex risks — from offshore structures and PEP involvement, to false filings on the Register of Overseas Entities.
While Customer Due Diligence remains a cornerstone of compliance, it’s just one part of a much wider obligation.
Key actions include:
- Commissioning a full review of AML policies, controls and procedures — especially for firms dealing with high-risk clients or cross-border transactions.
- Conducting enhanced due diligence where red flags exist, including high risk jurisdictions, complex opaque structures or political exposure.
- Verifying beneficial ownership thoroughly, even where companies appear on the ROE.
- Maintaining robust, auditable records to demonstrate how risk has been assessed and mitigated.
- Preparing and submitting Suspicious Activity Reports (SARs) when necessary.
Final thoughts
The UK property market remains a key global destination for investment — both legitimate and illicit. Transparency International’s report is a stark reminder of the ongoing risks and the need for meaningful due diligence.
At FCS Compliance, we work closely with businesses across the property sector to navigate the complex world of AML regulation. From training and audits to outsourced compliance support, we help firms not only meet their obligations, but protect their reputation.
If your business deals with high-value transactions or international clients, now is the time to review your AML controls – before the regulators do.
If you need support, please get in touch here
[1] https://www.transparency.org/en/news/dirty-money-hiding-spots-how-corruption-funds-disappear-overseas-billions-africa-assets?utm_source=linkedin&utm_medium=social&utm_campaign=africa%2Cregional%2Cdirtymoney
[2] https://www.transparency.org.uk/news/new-analysis-reveals-role-overseas-territories-pumping-almost-ps6-billion-dirty-money-uk
