- December 1, 2025
- Posted by: FCS Compliance
- Category: Blog, Property Market
As 2025 draws to a close, it’s clear this has been one of the most significant years yet for AML in the UK property sector. From new sanctions obligations for letting agents to upcoming changes to the Money Laundering Regulations (MLRs) and high-profile “dirty money” cases, property professionals have been searching for practical, real-world guidance more than ever.
Together, the articles you read, shared and returned to most often paint a clear picture of what estate and letting agents were concerned about.
Three themes jump out:
- Sanctions moved centre stage – especially for lettings agents
- The rules themselves felt “in motion” – with upcoming changes to the Money Laundering Regulations and a new National Risk Assessment
- Real-world risk remained prevalent – from multi-million-pound property freezes to stark data on illicit finance in UK real estate
Here’s what you were reading – and what it says about the year we’ve just had.
1. Sanctions Move Centre Stage for Letting Agents
Unsurprisingly, the most-read pieces this year were those dealing with the May 2025 sanctions changes for letting agents.
Our article on the May 2025 sanctions deadline set out what the new rules mean in practice, including mandatory screening of all landlords and tenants, robust record-keeping, and an explicit duty to report to the Office of Financial Sanctions Implementation (OFSI) where there is knowledge or reasonable suspicion of a sanctions breach.
This was followed by The OFSI Changes: 9 Common Questions Letting Agents Ask, which addressed the real-world questions coming through our training sessions and AML hotline. Agents wanted clarity on issues such as:
- Who needs to be screened, and when?
- How often should the sanctions status be re-checked?
- What happens if a historic sanctions issue is discovered on an existing tenancy?
Combined with New Rules, New Risks: 5 Estate Agent Watchouts for 2025, which highlighted, among other cases, a £15,000 sanctions penalty linked to a tenancy that began in 2016, and the message became unmistakable: sanctions compliance is now central to day-to-day AML risk management, especially in lettings.
2. “Are the Rules Changing?” — The Evolving Money Laundering Regulations (MLRs)
A second major theme was keeping pace with the shifting regulatory landscape, particularly around the future of the Money Laundering Regulations.
In July, our article Upcoming Changes to the UK Money Laundering Regulations broke down HM Treasury’s proposed reforms following its consultation on improving the effectiveness of the MLRs. The direction of travel was clear: a more targeted, proportionate and risk-based regime, with sharper expectations in higher-risk areas.
For many readers, the key takeaway was that doing the basics well and documenting your risk-based decisions will matter more than ever. The changes are not about adding layers of box-ticking, they’re about sharpening the focus on where your business genuinely faces higher risk.
Read alongside New Rules, New Risks: 5 Estate Agent Watchouts for 2025, it’s clear that 2025 was a year in which agents needed to keep one eye on today’s rules and the other on the regulatory reforms coming over the horizon.
3. Client Risk Assessments: From Paperwork to AML Decision-Making
If sanctions generated urgency, client risk assessments were the topic agents searched for and shared most consistently.
Understanding Client AML Risk Assessments – What You Really Need to Know tackled a question we hear constantly: “What should a client risk assessment actually look like in practice?” The article emphasised that a risk assessment is not just a form to complete. It is your opportunity, and obligation, to ask:
“Does this client or transaction pose a risk of money laundering or terrorist financing?”
It also reinforced some key principles:
- Every client should be risk-assessed, not only overseas or high-value ones
- Your assessment should determine whether simplified, standard or enhanced due diligence is required
- A well-documented assessment is one of your strongest defences if HMRC or the NCA later investigate
Combined with our analysis of the 2025 National Risk Assessment and the broader AML risk landscape, it’s clear that firms are increasingly embedding risk-based thinking into everyday onboarding, not just into firm-wide documentation.
4. Dirty Money, Property Freezes & Real-World AML Enforcement
Two of this year’s most-read articles showed how strongly property professionals engage when AML responsibilities collide with real-world cases.
In June, our explainer on the £170m UK property freeze broke down the NCA’s action involving more than 300 UK properties linked to Saifuzzaman Chowdhury and associated figures. It explored what the case reveals about how criminals use UK real estate — and what estate agents are expected to spot.
Meanwhile, UK Property and Dirty Money: A Closer Look at the Risks and Realities examined Transparency International UK’s findings that more than £11 billion in suspicious wealth has been linked to UK property since 2016. The article connected that data directly back to day-to-day Customer Due Diligence, underscoring the point that CDD is not a legal hoop — it is the frontline defence against illicit finance.
Later articles, including UK Property Market & AML: Insights from the 2025 National Risk Assessment and AML Risks for Estate Agents: The Bigger Picture, highlighted how regulators, campaigners and government now consistently position the property sector at the centre of the UK’s fight against illicit finance, especially relating to opaque ownership, trusts and collective investment structures.
Together, these pieces show that AML for property professionals is no longer a niche compliance matter. It has become a mainstream public-policy priority — and the sector’s role is under sustained scrutiny.
5. What This Tells Us – And What’s Next
Looking back over the year’s most popular articles, a clear pattern emerges:
- Agents want clear, practical guidance on new obligations
- The 2025 compliance and regulatory landscape has and will continue to shift
- Real-world cases and data continue to shape what “good AML” looks like in practice
The positive message is that the property sector is not avoiding these challenges. The engagement we’ve seen through article readership, hotline queries and training attendance shows a sector that is taking AML seriously and looking for ways to make compliance something that protects, rather than burdens, the business.
Looking Ahead to 2026
Next year, we will continue to:
- Track and interpret regulatory changes affecting estate and letting agents
- Share practical tools and explainers on topics like client risk assessments, screening, and CDD on complex structures
- Use case studies and real-world examples to keep AML guidance grounded in actual practice
If you want help preparing for the 2026 AML reforms, sanctions screening duties or client risk assessments, we’re here to support you. And as always, if there are topics you’d like us to explore in more depth next year, we’d love to hear from you.
