Monday, January 27, 2020


Confirm ownership of the Property – HMRC expect you to have a clear process to verify who owns the properties you are marketing. Obtaining the title register for the property is the route HMRC outline in their guidance and so the £3 cost of the document can be money well spent.

Conduct Customer Risk Assessments – HMRC guidance expects agents will do these risk assessments and penalties can be imposed if you don’t. They are quite simple to do and doing them can make compliance easier and quicker. The CDD steps required for a low-risk customer are much less onerous than those for a high-risk customer and most of your customers will be low risk.

Establish whether a customer is Politically Exposed – Anyone who is a PEP is to be assessed as high-risk according to the Money Laundering Regulations.  The chances of a customer being a PEP are very, very low, but all regulated business must have a procedure in place to check for this.

Give yourself an option to be able to use an Electronic ID Confirmation Service – Whilst this is not mandatory (as many of the sales staff from some providers will tell you) it is very useful to have the option for two reasons; firstly, some customers are not the most co-operative and so using this route can solve the problem and secondly, in higher risk situations using the service ensures you meet your enhanced due diligence requirement.  

Don’t believe everything you read in the press – Self-proclaimed AML experts started appearing from everywhere when compliance became more of a priority for agents. Unfortunately, a little knowledge can be dangerous and the advice they give is a little concerning and not always correct. When a salesperson from a company trying to sell you compliance services advises you that you must take their services or risk large HMRC penalties be a little wary!