In the penalties HMRC published in February 2026 (covering April to September 2025), agents picked up 369 penalties totalling £1.88 million. Estate agents were the hardest hit of any sector: 170 penalties worth £835,842. The uncomfortable truth for any agency owner reading this: almost none of those fines were for actual money laundering. They were for not having the paperwork.
What agents actually get fined for
HMRC's data is unusually clear about cause. In order of frequency:
- Trading while unregistered (Reg 56) — by far the biggest. You must register before you carry out estate or letting agency work; the review can take up to 45 days.
- Customer due diligence (Reg 28) — not properly identifying and verifying who you're acting for.
- Policies, controls & procedures and risk assessment (Reg 18–21) — nothing written down, or written and ignored.
And since 1 December 2025, every civil penalty carries an extra £2,000 sanctions-admin charge on top — with directors able to be named personally under Reg 78.
The 3 documents HMRC checks first
If an HMRC officer looked at your agency tomorrow, these are the first things they'd ask for:
- 1. Proof you're registered — your HMRC AML supervision registration, in place before you traded.
- 2. Your written risk assessment — a business-specific assessment of your money-laundering risk (Reg 18). Here's how to write one, with a template →
- 3. Your policies, controls & procedures — the document that says how you actually do CDD, screening, reporting and training (Reg 19–21).
That's it for the first hurdle. The agencies that sail through aren't doing anything clever — they simply have these in place and can produce them the same day.
Where do you stand right now?
Two minutes will tell you. Our free estate-agency AML self-check scores you and lists your biggest gaps — no email wall. If you'd rather just get compliant, our editable AML pack for estate & letting agents contains the risk assessment, policies, nominated-officer and CDD documents written to the regulations, ready to tailor. Either way, the goal is the same: be the agency whose answer to HMRC is "yes, here it is."
HMRC has fined estate agents over £835,000 — mostly for missing paperwork, not criminal wrongdoing. A consultant charges £1,000–£3,000 for the same documents.
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