The majority of UK estate agents could now be at risk of breaching anti-money-laundering (AML) laws following sweeping changes introduced by HMRC last month, Coadjute has warned.

The revised AML guidance, published on 9th September, transforms dozens of previously advisory checks into mandatory obligations.

The updated 200-page document uses the word ‘must’ 212 times and introduces a checklist of 34 named risk indicators that agents are now legally required to address in their Business Risk Assessment (BRA) and Policies, Controls and Procedures (PCPs).

According to Coadjute’s Chief Operating Officer, John Reynolds, any agency that hasn’t updated its AML documentation and onboarding processes since the new rules came into effect is likely to be non-compliant –  and could face fines of up to £158,000, based on recent HMRC enforcement actions.

Don’t cut it

“In recent weeks we’ve seen growing confusion across the industry,” said Reynolds. “Agents are receiving audit requests and warning notices, and many are realising their existing AML files and policies simply don’t meet the new benchmark.

If you’re still doing what you’ve always done, you may now be breaking the law.”

“If you’re still doing what you’ve always done, you may now be breaking the law.”

Reynolds added that the regulator’s framework explicitly flags high-risk patterns such as offshore entities, intermediaries, remote onboarding and third-party payers, while making clear that digital ID tools and sanctions look-ups alone are no longer sufficient.

“Tick-box apps and partial checks don’t cut it anymore,” he said.

Coadjute, which digitises property transaction workflows, is urging agents to professionalise or outsource their AML compliance to mitigate risk.

“Just as agents outsource payroll or EPCs, AML now needs specialist handling,” Reynolds added. “The new rules make ad-hoc compliance impossible to defend. Getting it right protects not just your licence but your brand.”