AML Compliance in UK Estate Agencies: Insights from the Experts on the Frontline

Frontline Insights: Stephen Williamson, Lead AML Consultant at FCS Compliance, shares key takeaways from recent client engagements and their implications for the property market.

In the last few weeks, I’ve had the chance to get out from behind the desk and into estate agency offices across the UK – from London to Edinburgh, via Nottingham – delivering AML (anti-money laundering) compliance training, reviewing live client files, and stress-testing compliance processes. It’s been a reminder that while AML (anti-money laundering) obligations under the UK’s Money Laundering Regulations are often viewed through the lens of policy documents and online checklists, the reality on the ground is far more nuanced. I wanted to share a snapshot of what that looks like, what estate agents are grappling with, how we help, and what others might take away from it.

Bespoke MLRO Training & File Review – Multi-Branch Sales and Lettings Agency (Nottingham)

This session combined two hours of targeted Money Laundering Reporting Officers (MLRO) training with four hours of hands-on AML consultancy. We worked through real client files, examined internal AML policies, and identified where theoretical procedures didn’t quite match the day-to-day challenges staff were facing.

What stood out most was the openness of the team in discussing grey areas – how far to go on source of funds checks, how to assess risk when dealing with long-standing clients, and when to escalate concerns. These conversations often highlight where an AML policy might be technically compliant, but operationally fragile. Being able to unpick those challenges face to face means we can suggest small changes that deliver big impact – whether that’s tweaking a client due diligence (CDD) checklist or clarifying internal escalation routes.

Customer Due Diligence (CDD) Workshop – Multi-Branch Sales and Lettings Agency (Various Locations, Scotland)

Workshops like this are always a great reminder that AML training for estate agents doesn’t have to be dry or abstract. We structured the session around practical case studies and round-table discussions. What made it particularly effective was that several participants brought along real cases they’d handled, allowing us to work through them together.

It also raised useful debate around different models of due diligence. As the agency is currently exploring a revised internal structure, we used the session to help them think through how that structure could be embedded in practice – ensuring that any changes would still support a compliant and workable AML process. It’s that blend of flexibility and structure that keeps sessions relevant, especially when no two agencies do things exactly the same way.

Customer Due Diligence (CDD) File Review – Prime Central London Buying Agent

In contrast to group training, this was a quieter, focused half-day spent combing through live customer due diligence (CDD) files. The client wanted a fresh set of eyes on a selection of cases to test whether the evidence truly backed up their AML risk ratings – and whether any gaps were being inadvertently missed.

This kind of review often reveals subtle issues: expired ID documents not followed up, source of funds explanations that sound plausible but aren’t properly evidenced, or missing rationale on why a politically exposed person (PEP) was rated as low risk. By the end of the session, we’d compiled a short list of practical fixes – nothing groundbreaking, but all things that could make a big difference under scrutiny from HMRC in an AML inspection.

Mock HMRC Inspection – North London Sales and Lettings Agency

This full-day session replicated the pressure of a real HMRC AML inspection, but with the safety net of being a rehearsal. We reviewed all the essentials: AML policy, firm-wide AML risk assessment, training logs, client files, and staff knowledge. The aim wasn’t just to find gaps, but to build confidence – helping the team understand how to articulate their AML compliance framework and respond effectively to questioning.

Interestingly, some of the most valuable learning came not from documentation, but from walking through processes – how client onboarding is handled in reality, where decisions get made, and how those decisions are documented (or not). These are often the points where inspections falter – not because firms don’t care, but because their AML systems and controls haven’t been pressure-tested in a while.

Why Share All This?

There’s no one-size-fits-all approach to AML compliance, especially in the UK property sector. But across these sessions, a few themes emerged: the value of practical discussion, the importance of joining up paper policies with real-world action, and the power of an outside perspective to spot the blind spots that become invisible over time.

Whether through structured training, a file review, or a mock inspection, the firms we worked with didn’t just ‘tick a box’ – they walked away better equipped to protect their businesses and respond to regulatory scrutiny. That’s something I think every estate agency should feel empowered to do.

If this article gives you ideas or raises questions, feel free to get in touch – I’m always happy to talk. Call us on +44 (0)20 7924 7979 or email us at info@fcscompliance.co.uk.

Some important key takeaways from this article

• Ensure your AML policy reflects day-to-day operations: AML documents only work if they reflect what actually happens on the ground.
• Engage your team: Giving staff the space to question grey areas can strengthen your AML compliance culture and reduce hesitation in real-life cases.
• Audit yourself before someone else does: Mock inspections and file reviews can reveal compliance gaps before HMRC does – and help build confidence across the team.
• No two agencies are the same: Tailoring training and processes to your business model isn’t a luxury – it’s a necessity for effective AML compliance.
• Even small fixes matter: A missing document or an unclear risk rating might seem minor, but it’s often these small details that define whether you’re HMRC inspection-ready.