- September 29, 2025
- Posted by: FCS Compliance
- Category: Blog, Property Market
The UK Government’s 2025 National Risk Assessment (NRA) shines a fresh spotlight on the property sector as a critical route for money laundering. For estate agents and residential property professionals, the message is clear: understanding and responding to these risks is not optional.
Opaque Ownership Still a Top Threat
Property remains a major channel for illicit finance, with Transparency International estimating that £11 billion of suspicious wealth has been linked to UK properties since 2016. The most persistent enabler of this activity? Complex ownership structures.
While previous efforts like the Register of Overseas Entities (ROE) have targeted secretive shell companies, attention is now turning to trusts. These arrangements often obscure the Ultimate Beneficial Owner (UBO) and their source of wealth, making it harder for estate agents to spot red flags.
Cited in the NRA is research showing that over 170 UK properties, worth £2.5 billion, were acquired using opaque trust structures linked to suspicious wealth.
Additionally, collective investment vehicles such as REITs and OEICs are flagged as areas of emerging concern, with pooled funds providing another potential veil for anonymous ownership.
Emerging risks also include collective investment vehicles like Real Estate Investment Trusts (REITs) and open-ended investment companies (OEICs), which can add another layer of anonymity. For property professionals, the expectation is clear, when companies, trusts, or pooled funds are in play, you must have the expertise to recognise the risks, and the confidence to know when enhanced due diligence is essential.
The Role of Professional Enablers
Another major risk theme identified in the NRA is the rise of “professional enablers.” These are individuals or organisations – including estate agents – whose services can (knowingly or not) facilitate money laundering.
The concern is not only deliberate misconduct but also negligent or inadequate AML practices. With estate agents supervised by HMRC, the expectation is that firms implement and maintain strong AML controls. Failure to do so could lead to enforcement action – or worse, reputational damage.
The report highlights the need for stronger and more consistent supervision across non-financial sectors. Property professionals should expect more scrutiny and higher expectations in the months ahead. For more background on penalties and supervision, see our article on HMRC’s enforcement approach.
Preparing for Reform
The NRA isn’t just a warning; it lays the groundwork for change. On the same day as its release, the Government confirmed plans to increase transparency around overseas trusts holding UK property, alongside broader reforms to the Money Laundering Regulations.
These developments signal a tightening landscape. Estate agents will need to demonstrate not only compliance, but a proactive approach to risk management, particularly when handling:
- Trust-owned properties
- Complex or layered corporate structures
- Clients or funds from high-risk jurisdictions
Why This Matters for Day-to-Day Practice
For property professionals, these findings translate into practical realities. Client onboarding processes will likely become more detailed, with a greater emphasis on documenting beneficial ownership and verifying the source of funds. Firms that lack a clear and consistent process for handling complex structures risk falling behind – or worse, being held liable if illicit wealth passes through their business.
Just as importantly, the NRA reinforces the importance of staff training. Frontline teams need to be confident in spotting red flags, challenging unusual ownership arrangements, and knowing when to escalate concerns. Without a strong culture of compliance, even the best-written AML policies are unlikely to be effective.
Strengthen Your AML Defences
At FCS Compliance, we work with hundreds of estate agents across the UK to ensure their anti-money laundering controls are fit for purpose.
The NRA makes clear that enforcement is tightening. The best way to protect your business is to act now. Book an AML audit today to benchmark your compliance, identify gaps, and get ahead of HMRC’s expectations.
Contact our team to speak with a compliance consultant and safeguard your business against the risks highlighted in the NRA.
