Estate Agents should by now be aware of their obligations under the UK Money Laundering Regulations which came into force in June 2017, not only to undertake due diligence on their clients and customers, but also on counterparties to any relevant sale and purchase. What seems to be surprisingly unknown is that Estate Agents, which catches all those involved in sales and purchases were obliged, by 1 April 2018 to register with HMRC, as the sectoral supervisory authority for Anti-Money Laundering purposes.
A failure to register is a legal breach which can give rise to a fine. Numerous fees apply including a one off application charge, a registration fee for each premises, a fit and proper test fee for each person tested and an approval process fee. Assuming one office and two individuals to be “fit and proper” the overall fee is £410 together with an annual renewal fee of £130. In addition to registration, Estate Agents must appoint a Money Laundering Reporting Officer as well as a deputy, who must be members of the management team and be appropriately trained and updated on the rules and requirements.