Letting agents
Letting Agent AML Compliance: Sanctions, Due Diligence and OFSI
AML compliance for letting agents is one of the most misunderstood duties in lettings — partly because there are really two separate obligations wearing the same name. This guide separates them: the sanctions screening every agent must do, and the anti-money-laundering supervision that applies to higher-value lettings.
This is general information, not legal advice. Where rent thresholds are given they follow the Money Laundering Regulations as applied to letting agency business.
Sanctions screening: every agent, every let
Since 14 May 2025, financial sanctions reporting obligations apply to all letting agents. In practice this means you must check that landlords, tenants and guarantors are not on the UK Sanctions List before and during a let, regardless of the rent. This duty is universal — it does not depend on any threshold.
- Screen every party to the tenancy against the current list.
- Re-screen periodically, as designations change frequently.
- Keep a timestamped record of each check and its result.
AML supervision: high-value lettings
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)treat a letting agent as a regulated “letting agency business” where the monthly rent is €10,000 or more. If that applies to any of your properties you must:
- Register with HMRC for AML supervision.
- Carry out a written firm-wide risk assessment.
- Run customer due diligence (identify and verify the parties, understand the source of funds where needed).
- Appoint a nominated officer and train staff.
- Keep records for the required retention period.
Reporting and OFSI
If you identify a sanctions match, you must not proceed, must freeze any relevant dealing, and must report to OFSI (the Office of Financial Sanctions Implementation). Dealing with a designated person, or making funds available to them, is a criminal offence — so a reliable screening and reporting process is essential.
How Vantage helps
Vantage downloads the UK Sanctions List daily and screens tenants, landlords and guarantors with fuzzy name matching that follows OFSI guidance, flagging potential matches and recording a timestamped audit trail for every check. It is part of the wider letting agent compliance picture — see also GDPR compliance for letting agents.
Frequently asked questions
Do letting agents have to do AML checks?
All letting agents must screen against the UK Sanctions List on every party to a let — this has been mandatory since 14 May 2025 and applies regardless of rent level. Separately, letting agents whose monthly rent on a property is €10,000 or more are 'letting agency business' under the Money Laundering Regulations and must register for HMRC AML supervision and carry out customer due diligence.
What is the difference between sanctions screening and AML supervision?
Sanctions screening is a universal duty: you must check that the people you deal with are not on the UK Sanctions List, and it applies to every letting agent. AML supervision under the Money Laundering Regulations is narrower — it applies to high-value lettings (monthly rent of €10,000+) and requires HMRC registration, risk assessments and customer due diligence.
What do I do if a tenant matches the sanctions list?
Do not proceed with the let, freeze any dealing with the funds or assets, and report the match to OFSI (the Office of Financial Sanctions Implementation). Keep a record of the check and the match. Dealing with a designated person, or making funds available to them, is a criminal offence.
Stop struggling with lettings compliance
Vantage gives every property a 0–100 compliance score, recommends and guides actions by priority, and reminds you before each obligation is due. For just £0.80 per property per month.