Anti-Money-Laundering Supervision for Estate Agents: HMRC Registration, Fees and Compliance Obligations

Estate and letting agency businesses operating in the United Kingdom are subject to anti-money-laundering supervision by HMRC. This regime, established under the Money Laundering Regulations 2017, imposes registration requirements, periodic fees, and ongoing compliance obligations on firms that fall within its scope. With fee changes effective from 1 December 2025, and HMRC continuing to enforce the regime, agents may wish to review their position and verify their obligations against the official guidance.

Who must register with HMRC for anti-money-laundering supervision?

Estate and letting agency businesses must register for anti-money-laundering supervision with HMRC under the Money Laundering Regulations 2017. The definition of an "estate agency business" for these purposes is detailed in the official registration guide, and agents may wish to review that guidance to determine whether their activities fall within scope.

One suggested approach is to verify scope and applicability with HMRC or a compliance adviser before assuming exemption. The Regulations apply to a broad range of property transactions, and the registration guide sets out which business models and transaction types trigger the obligation. Agents often choose to seek confirmation early rather than risk non-compliance.

HMRC registration fees and the December 2025 update

HMRC fees for HMRC anti-money laundering registration for estate agents were updated on 22 December 2025, with effect from 1 December 2025. The current fee structure, as set out in the registration fees guidance, comprises:

• A £300 one-off registration fee;
• A £400 annual fee per premises; and
• A £40 approval-process fee per beneficial owner, officer, or manager.

A small-business reduction applies where turnover is under £5,000. Agents may wish to check their eligibility against the criteria at the fees guidance link above. One suggested approach is to budget for both initial and recurring annual premises fees, especially for multi-branch agencies, and to factor the £40 per-person approval fee into succession or staffing plans.

Core compliance obligations under the Money Laundering Regulations 2017

Registered businesses face four core ongoing obligations under the Regulations: maintaining a written risk assessment, conducting customer due diligence, appointing a nominated officer, and submitting Suspicious Activity Reports to the National Crime Agency. These responsibilities are detailed at https://www.gov.uk/guidance/money-laundering-regulations-your-responsibilities, and agents may wish to review each element against their own policies and procedures.

One suggested approach is to document each compliance measure and review it periodically, particularly when business structure or client profiles change. Agents often choose to maintain accessible records in case of HMRC inspection or internal audit.

Risk assessment: a suggested approach

A written risk assessment is a core requirement under the Regulations. Agents often choose to assess risks specific to their business model, geography, client base, and transaction types. The risk assessment should identify areas where money laundering or terrorist financing may occur, and set out the controls the business has in place to mitigate those risks.

One suggested approach is to review and update the risk assessment annually or when significant business changes occur, and to retain records in case of HMRC inspection. Many agents also find it helpful to involve senior management and the nominated officer in the assessment process.

Customer due diligence and the nominated officer role

Customer due diligence is another core obligation, and agents may wish to establish clear procedures for identity verification and record-keeping. The responsibilities guidance explains the types of information and documents that may be relevant, and agents are encouraged to verify the detail before relying on any particular approach.

Appointing a nominated officer responsible for anti-money-laundering compliance is required under the Regulations. This individual oversees the firm's compliance programme, receives internal reports of suspicious activity, and decides whether to file a Suspicious Activity Report with the National Crime Agency. The £40 approval-process fee applies per beneficial owner, officer, or manager, so agents may wish to factor this into succession or staffing plans.

One suggested approach is to train the nominated officer and keep them informed of regulatory updates from HMRC and the National Crime Agency.

Suspicious Activity Reports and ongoing supervision

Where agents suspect money laundering or terrorist financing, submitting a Suspicious Activity Report to the National Crime Agency is a core obligation. Agents may wish to establish internal escalation procedures so that concerns reach the nominated officer promptly and are assessed in line with the firm's risk assessment and policies.

HMRC conducts ongoing supervision of registered businesses, and one suggested approach is to retain all compliance documentation and be prepared to demonstrate adherence during any review. Agents are encouraged to verify all procedural and reporting requirements against the official guidance at https://www.gov.uk/guidance/money-laundering-regulations-your-responsibilities before taking action, and to consult a compliance adviser or solicitor for case-specific advice.