Anti-money laundering: Suspicious Activity Reports filed by agents only 0.2% of total

The number of estate agents reporting potential money laundering activities has risen but still represents only a tiny proportion of all reports.

A new report says that in the 18 months between October 2015 and March this year, there were 766 Suspicious Activity Reports by estate agents.

This represented just 0.2% of the total number of the 634,113 reports during the period.

The 18-month figure compares with a 12-month period when the National Crime Agency reported that between October 2015 and September 2016, there were 514 reports by estate agents, again representing just 0.2% of the total.

Banks and building societies were the biggest reporters of suspicious activity during both periods.

While estate agents are almost at the bottom of those industries that need to report money laundering suspicions, the number has risen – possibly in part due to increased awareness following the C4 From Russia With Cash programme, where undercover filming of agents with a clearly dodgy Russian buyer, Boris, was shown in July 2015.

The National Crime Agency says that in the year 2014/2015, estate agents were responsible for just 355 reports.

Agents, financial institutions and law firms are responsible for sending suspicious activity reports (SARs) to the NCA as part of their anti-money laundering responsibilities to raise red flags when they detect potentially illegal activity such as overseas property buyers paying in cash.

The latest figures represent the period before the Fourth Anti-Money Laundering and Terrorist Financial Directive was brought into force in June 2017, which says estate agents must now perform checks on both buyers and sellers and can receive unlimited fines for failing to do so. Letting agents remain exempt from the new directive.

The latest National Crime Agency report is at

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  1. Chris Wood

    If an agent isn’t registered with HMRC AML they are highly unlikely to report any suspicious activity as doing so would incriminate themselves. There are now believed to be over 600 of these firms working for just one well-known franchise.

    (Note also the element about registration with the FCA if you are introducing loans or finance agreements.


    “It’s a criminal offence to trade as an estate agency business without being registered or after your registration is cancelled with HM Revenue and Customs (HMRC) for money laundering supervision.”

    Who must register
    You must register with HMRC if your business carries out any work defined as estate agency activity.
    Register your business if both of the following apply. You:

    act on instructions from a customer who wants to buy or sell commercial or residential property in the UK or abroad
    introduce your customer to a third party who wants to buy or sell a property in the UK or abroad

    Estate agency activities
    These include things like:

    sending out property details and arranging viewings
    offering personal advice to potential sellers or buyers
    answering questions from potential sellers or buyers
    passing on details to customers
    providing or arranging an energy performance certificate
    providing a property valuation
    providing a plan of a property and taking photographs
    providing customers with a ‘for sale’ board that includes the estate agency business contact details

    Businesses that must register
    The types of business that must register are:

    high street residential estate agencies
    commercial estate agencies
    online estate agencies
    , property or land auctioneers
    land agents
    relocation agents, property finders, private acquisitions specialists
    a sub-agent providing estate agency services to a main estate agency business
    asset management businesses that also provide estate agency services
    business brokers or transfer agents brokering the sales or transfer of client businesses to third parties
    social housing associations that offer estate agency services
    letting or property management agents that offer estate agency services to landlord customers
    construction companies (residential property builders) with a sales offices on-site, where they act or offer additional estate agency services other than the sale of their own construction properties
    a solicitor’s property centre in Scotland

    When you don’t need to register:
    You don’t need to register if you’re:

    a lettings agent only carrying out lettings work
    an auctioneer already registered with HMRC as a high value dealer
    publishing adverts or distributing information, for example in a newspaper
    an intermediary, like an internet property portal for private sales, allowing private sellers to advertise their properties and letting sellers and buyers to contact each other (but only if you do nothing else covered by the general definition of estate agency work)
    a solicitor carrying on estate agency work as part of that practice as a solicitor, and not as a separate business

    An estate agency business may be regulated by the Financial Conduct Authority (FCA) for another purpose, for example because they provide consumer finance or hire purchase services. In this situation HMRC and the FCA will consider the possibility of a single supervisor overseeing the anti-money laundering arrangements. Supervision for individual businesses will be looked at on a case by case basis.
    If you’re an appointed representative of a business that’s authorised by the FCA, then the FCA won’t be your supervisor and you must register with HMRC.”


  2. Anthony

    We reported someone once, we are highly suspicious that nothing was done with the information and don’t get me started on how poor “right to rent” is, if you make reports to them. Absolutely dire…no confidence that either organisation have the training or mojo to do the job that Government intended. Waste of time.


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