Is Money Laundering alive and well in the UK property market?

Added 05/10/26 - 3 min read

Originally published 11/04/19

Is Money Laundering Still Alive and Well in the UK Property Market?

Property is still one of the sectors HMRC and the FCA rate as highest risk for money laundering, and the reasons haven't changed: high transaction values, complex ownership structures, and a chain of professionals, broker, solicitor, lender, estate agent, where it's easy for everyone to assume someone else has checked. What's worth a broker's attention isn't the theory, it's what to actually notice on a case in front of you.

What to watch for on the transaction itself

Most of the risk shows up in ordinary case detail rather than anything dramatic. Worth a second look: a deposit or funding structure that doesn't sit well with what you know about the client's circumstances, money arriving from several people or accounts without a clear explanation, or a third party providing funds who seems reluctant to be identified. The same applies to a bank account changing partway through a transaction, pressure to complete quickly with normal checks skipped, or details that don't quite match between what's been told to you, the lender, the solicitor and the estate agent. None of these prove anything on their own. Together, or unexplained, they're worth raising rather than working around.

Company and overseas ownership: who's really behind the purchase

Buy to let and corporate cases add another layer. It's worth pausing where an applicant can't clearly explain who owns or controls the company involved, where the person providing the deposit isn't the shareholder or director without an obvious reason, or where a recently formed company is being used for a high value purchase. The same goes for ownership running through an overseas company or trust. Since the Economic Crime and Corporate Transparency Act 2023, there's a more concrete way to check this: whether the entity is registered on the Register of Overseas Entities, and whether its ownership has been through Companies House identity verification. Both give a more reliable answer than relying on the documents supplied alone.

The basics that catch what everything else misses

Underneath all of the above, the basics matter most. That means verifying client identity and, where relevant, source of funds, rather than accepting an explanation at face value. In higher risk cases, it's also worth understanding the source of wealth, how the client's overall financial position has built up over time, not just where this specific payment came from.

It means running PEP (politically exposed person) and sanctions screening consistently, ideally through a tool that plugs into your CRM rather than depending on memory. A screening match on its own isn't a reason to reject a case, it needs confirming as genuine first. It's worth checking that your brokerage's AML (anti-money laundering) policy reflects the FCA's current, more proportionate approach to PEPs and their associates (FG25/3, July 2025), rather than treating everyone connected to a PEP the same way. And it means treating an explanation that doesn't quite add up as worth a second look, not a box already ticked.

Where something doesn't sit right, the important part is knowing the route: raise it internally with whoever holds the MLRO (Money Laundering Reporting Officer) role at your brokerage, or, if you're working on your own, through your own documented process for deciding whether something needs reporting. Either way, keep a clear record of why a decision was made. For the specifics of what counts as suspicious and how a report should be handled, the Joint Money Laundering Steering Group's guidance and the National Crime Agency's own resources are the sources to check directly.

Building this into everyday practice

So yes, money laundering is still very much alive in the property market, and it's still relying on exactly the dynamic regulators keep flagging: everyone in the chain assuming somebody else has already checked. A broker isn't expected to run an investigation. The job is noticing when an explanation and the evidence behind it don't quite form a coherent picture, and knowing where to take that when it happens.
Stay up to date with compliance issues, so you can be sure you're following all the latest requirements that affect you or your business.

Listen to our podcast on staying cyber smart as a broker for a related look at protecting your brokerage against financial crime - Cyber Smart for Brokers

Or take a look at How to create a culture of compliance within your firm for a wider view of embedding these checks into everyday practice.

Sources: