HMRC publishes revised anti-money laundering guidance reflecting June regulatory changes

HMRC published updated anti-money laundering guidance for supervised businesses on 16 July 2026, reflecting changes introduced by statutory instrument SI 2026/621, which took effect on 30 June 2026. Estate and letting agents supervised by HMRC under the Money Laundering Regulations 2017 may wish to review the revised guidance to confirm that their customer due diligence procedures, risk-assessment documentation, and staff training materials remain aligned with the current regulatory framework.

What changed

The revised HMRC guidance clarifies obligations under the Money Laundering Regulations 2017 in light of the changes brought into force by SI 2026/621. Agents may wish to verify the specific amendments introduced by the statutory instrument directly against the published guidance on GOV.UK before updating internal policies or training materials. One suggested approach is to compare current customer due diligence procedures against the revised guidance to identify any gaps, and to confirm with your firm's Money Laundering Reporting Officer (MLRO) that risk-assessment documentation reflects the updated regulatory requirements.

Who is affected

All estate and letting agents registered with HMRC for anti-money laundering supervision under the Money Laundering Regulations 2017 are within scope of the updated guidance. This includes both sales and lettings practices, sole traders, partnerships, and corporate entities that meet the definition of "estate agency business" under the Estate Agents Act 1979 or carry out lettings activities as defined in the Regulations.

Context: continuing enforcement and sector focus

The updated guidance arrives against a backdrop of sustained enforcement activity. HMRC fined 170 estate agents a total of £835,000 during the first half of 2025 for anti-money laundering failures, and recent tribunal decisions confirm that breaches of customer due diligence, risk-assessment, and record-keeping obligations continue to attract significant financial penalties. A July 2026 case reported by FCS Compliance on 2 July highlighted alleged AML and sanctions-screening failures in connection with a £150 million London property portfolio assembled for Iranian elites, underscoring the importance of robust source-of-funds verification and politically exposed persons (PEPs) checks—particularly in high-value and prime-market transactions.

Supporting guidance and training resources

Alongside the HMRC update, agents may wish to note that Propertymark published guidance on Suspicious Activity Reports (SARs) on 5 July 2026, emphasising the role of SARs in preventing money laundering in the property sector. All agents supervised by HMRC are required to submit SARs to the National Crime Agency when they know or suspect that client activity involves criminal property; agents may wish to review the Propertymark guidance with their MLRO and verify that client-facing staff understand the threshold for submission (knowledge or suspicion, not proof).

In addition, HM Treasury announced updates to the Money Laundering Regulations in June 2026, and a free AML webinar for property professionals was made available (reported by Property Industry Eye on 10 July 2026). Agents may wish to consider attending the session to verify their understanding of the regulatory changes and their application to their business.

Suggested approaches to consider

Agents may wish to:

• Review the updated HMRC AML guidance published on 16 July 2026 to confirm the changes introduced by SI 2026/621 from 30 June 2026.
• Compare current customer due diligence procedures against the revised guidance to identify any gaps or areas requiring clarification.
• Verify with the firm's MLRO that risk-assessment documentation reflects the updated regulatory requirements, and that the risk assessment is reviewed annually or when business structure or client profiles change.
• Check that staff training materials and induction resources reference the current version of HMRC's AML guidance, and consider scheduling refresher training if the last session pre-dates the June 2026 regulatory changes.
• Confirm that the firm's AML policy documentation reflects current SAR obligations under MLR 2017, and that the SAR submission process uses the National Crime Agency's online reporting portal.
• For agents handling high-value sales or lettings, particularly in central London and other prime markets, review sanctions-screening processes to ensure that beneficial owners and linked parties are checked against HM Treasury's UK Sanctions List and OFSI consolidated lists, and that enhanced due diligence is applied to politically exposed persons (PEPs) as required by MLR 2017 regulation 35.

Where to verify

Readers are encouraged to verify all details against the revised HMRC guidance at GOV.UK, the text of SI 2026/621, and the supporting resources published by Propertymark and Property Industry Eye, before taking any action. This article is for information only and does not constitute legal or compliance advice; agents may wish to consult a solicitor or specialist compliance adviser for case-specific guidance.