Financial Sanctions Checks: Updated Guidance
Previously, Lettings Agents have carried out sanctions checks where monthly rents exceed 10,000 euros under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended by the Money Laundering and Terrorist Financing (amendment) Regulations 2019 (collectively, “the Regulations”).
From 14 May 2025 onward, Lettings Agents are added to the list of "relevant firms" under The Sanctions and Anti-Money Laundering Act 2018.
What Does This Mean For Lettings Agents?
In addition to complying with Anti-Money Laundering (AML) obligations under the Regulations, Lettings Agents must:
- Conduct financial sanctions checks on all tenants, landlords and other relevant parties - regardless of rental value;
- Screen these parties against Government sanctions lists before entering into contracts and accepting payments; and
- Report to the OFSI if they know, or suspect, that a party is a designated person or has breached sanctions regulations. Reports are only required where the knowledge or suspicion arises in the course of conducting your business activities.
Failure to comply can result in significant financial penalties and imprisonment for up to seven years.
AML Compliance For Estate Agents
Estate Agents will already be familiar with their AML obligations, including financial sanctions checks under the Regulations.
New and Updated Documents
To support ongoing compliance, updated template AML policies, risk assessments and comprehensive Guidance Notes are now available for both commercial and residential Estate and Lettings Agents.
The contents of this Newsletter are for reference purposes only and do not constitute legal advice. Independent legal advice should be sought in relation to any specific legal matter.
