Iran Sanctions List Updated: Agents May Wish to Review Screening Procedures

The Iran (Sanctions) Regulations 2023 (SI 2023/1314) were amended on 3 October 2026, according to an update published on legislation.gov.uk. Estate and letting agents conducting customer due diligence under the Money Laundering Regulations 2017 may wish to verify whether the updated sanctions list affects their screening obligations, particularly when handling property transactions involving clients with potential links to sanctioned Iranian individuals or entities.

Readers should verify the detail of the updated Regulations directly on legislation.gov.uk before taking any action, and consult a solicitor for case-specific advice.

What changed

The Iran (Sanctions) Regulations 2023 were amended via an update published on 3 October 2026. The Regulations form part of the UK's sanctions framework, designating individuals and entities subject to financial restrictions and asset freezes. Estate and letting agents supervised by HMRC under the Money Laundering Regulations 2017 are required to screen clients against UK sanctions lists as part of their customer due diligence obligations.

No detail of which individuals or entities were added or removed is available in the source records provided. Agents may wish to consult the full consolidated text of SI 2023/1314 on legislation.gov.uk, HM Treasury's UK Sanctions List, and the Office of Financial Sanctions Implementation (OFSI) consolidated lists to confirm the current scope of the Iran sanctions regime and whether any of their clients or prospective clients are affected.

Who is affected

This update may be relevant to estate and letting agents conducting customer due diligence under the Money Laundering Regulations 2017, particularly those handling property transactions involving clients with potential links to sanctioned Iranian individuals or entities. Agents operating in central London and other prime markets where foreign investment and politically exposed persons are common may face heightened exposure to sanctions-screening obligations.

HMRC fined 170 agents a total of £835,000 during the first half of 2025 for anti-money laundering failures, underlining the regulator's focus on compliance with customer due diligence and sanctions screening.

Suggested approaches agents may wish to consider

One suggested approach is to review the updated Iran (Sanctions) Regulations 2023 on legislation.gov.uk to confirm whether any changes affect your sanctions screening obligations. Agents may wish to check whether their AML compliance software or screening provider includes the updated Iran sanctions list published on 3 October 2026, and to verify with their Money Laundering Reporting Officer (MLRO) that staff conducting customer due diligence are aware of the Iran sanctions regime and the escalation procedures for potential matches.

Agents may also wish to confirm that their current customer due diligence procedures align with the Money Laundering Regulations 2017 requirements for source-of-funds and source-of-wealth verification, and that their sanctions-screening process checks beneficial owners and linked parties against HM Treasury's UK Sanctions List and OFSI consolidated lists. The FCS Compliance case study published on 2 July 2026 – describing a sanctioned banker who allegedly assembled a £150 million London property portfolio for Iranian elites – illustrates the sector's exposure to sanctions-screening failures.

Agents may wish to verify that their firm maintains adequate records of source-of-funds evidence for transactions involving foreign nationals or complex ownership structures, as HMRC expects under regulation 40 of the Money Laundering Regulations 2017. Enhanced due diligence is required for politically exposed persons (PEPs) under regulation 35, and agents may wish to confirm with their MLRO that staff can identify PEPs and apply the necessary controls.

Broader AML enforcement context

The Iran sanctions update follows HM Treasury's publication of its 2026 Anti-Money Laundering Strategy on 20 September 2026, which flagged the property sector as a priority for enforcement and announced a move toward risk-based supervision. Estate and letting agents supervised by HMRC under the Money Laundering Regulations 2017 should expect closer scrutiny of customer due diligence, beneficial ownership checks, and suspicious activity reporting over the coming months.

Agents may wish to review their firm's customer due diligence procedures against the current HMRC guidance for estate agents (published August 2024), verify that all staff handling client onboarding can identify and escalate red flags for beneficial ownership and source of funds, and check that their most recent suspicious activity report (SAR) filing processes align with the National Crime Agency's SAR Online portal requirements.

WatchdogHQ is an information and awareness service. It is not legal advice and not a solicitor. Readers should verify all details against the primary legislation, official guidance, and the cited sources before taking action, and consult a solicitor for case-specific advice.