Property & estate agents
Estate agency businesses and letting agents handling monthly rents at or above the EUR 10,000 threshold are supervised by HMRC and are a stated priority under successive UK National Risk Assessments.
Where the regime bites
Both sales and letting agents (at the threshold) are 'relevant persons' under Regulation 13 of the MLR 2017. HMRC's Estate Agency Business (EAB) supervision team conducts risk-based inspections and publishes annual thematic findings.
The Economic Crime (Transparency and Enforcement) Act 2022 introduced the Register of Overseas Entities, and firms acting on any relevant property transaction with an overseas corporate buyer or seller must verify ROE registration before completion.
What supervisors expect
CDD on both the buyer and the seller (or landlord and tenant, where a lettings agent is in scope), completed at the point of acceptance of instruction.
ROE verification for all relevant property transactions involving overseas entities under ECTEA 2022, with the OE ID recorded on file.
Documented source-of-funds evidence, especially where deposits or completion monies come from third parties or non-UK accounts.
Annual HMRC registration renewal and premises-level fees paid, with beneficial owner, officer and MLRO (BOOM) fit and proper tests up to date.
Recurring risk indicators
- Overseas buyers using complex or opaque ownership chains
- Deposit funded by third parties without a clear commercial rationale
- Cash purchases and rapid resale ('flipping')
- PEP purchasers using nominee structures
- Under-market rentals and rent paid substantially in advance
Advisory support for the sector
- HMRC EAB inspection preparation
- Firm-wide and property-level risk assessments
- ROE and PSC integration into onboarding
- Staff training and attestation