AML Checks & Compliance Software for Estate Agents

 Estate agents should apply risk-based Customer Due Diligence to identify and verify customers and, where relevant, beneficial owners, understand the purpose of the transaction, and assess financial-crime risk. Depending on the customer and transaction, this can also include KYC checks, KYB checks, sanctions and PEP screening, Source of Funds or Source of Wealth checks, Enhanced Due Diligence and ongoing monitoring. 

Yes. HMRC’s current estate-agency guidance states that both the buyer and seller are customers for AML purposes. Estate agents should identify the relevant parties and complete appropriate CDD on each side of the transaction.

 Proof of funds demonstrates that a buyer has money available to complete a purchase, while Source of Funds looks at where the money being used for the transaction originated. They should not be treated as interchangeable: HMRC guidance takes a risk-based approach to verifying Source of Funds rather than stating that the same evidence must be obtained for every property transaction. 

Source of Wealth checks help establish how a customer accumulated their overall wealth. They may be appropriate during standard CDD, Enhanced Due Diligence or ongoing monitoring where the risk assessment indicates they are needed, and they form part of the required EDD measures for PEP relationships. 

Yes. HMRC is the AML supervisor for estate agency businesses, and estate agents carrying out relevant activity must be registered for money laundering supervision. The page should therefore reference HMRC guidance, rather than FCA guidance, when explaining estate-agent AML obligations.

KYC focuses on establishing and verifying who the customer is. Customer Due Diligence is the wider risk-based process that can include identity verification, beneficial-owner checks, understanding the purpose of the transaction, screening, risk assessment, and ongoing monitoring. HMRC notes that CDD is also sometimes referred to as KYC, so the page should explain the relationship rather than present them as entirely separate regulatory requirements.

Enhanced Due Diligence is required where a customer, relationship, or transaction presents higher money-laundering risk. Depending on the circumstances, EDD can involve additional identity verification, deeper Source of Funds or Source of Wealth checks, management approval, and enhanced ongoing monitoring.

Where the buyer or seller is a company or other legal entity, estate agents should identify and verify the entity and relevant beneficial owners as part of CDD. Complex corporate or ownership structures may also increase the level of risk and require additional investigation.

A potential screening result should be reviewed to establish whether it relates to the customer or beneficial owner. A PEP relationship requires proportionate EDD, while a confirmed sanctions match must be handled in accordance with the relevant UK financial-sanctions restrictions, reporting requirements and any applicable licensing rules.

Estate agents should retain the documents and information used to complete CDD, together with sufficient supporting records to demonstrate how relevant transactions and compliance decisions were handled. A centralised audit trail can make it easier to evidence checks, risk assessments, reviews and outcomes during an HMRC compliance inspection.

Yes. Digital identity verification can form part of an estate agent’s CDD process, provided the service meets the applicable requirements and gives sufficient assurance that the person is who they claim to be. Current 2026 guidance also requires relevant digital verification services used for MLR identity checks to meet the UK digital verification framework requirements, while the estate agent remains responsible for its CDD decisions.