Estate Agency Firm Wide Risk Assessment

This Template Estate Agency Firm Wide Risk Assessment is designed for use by residential Estate Agents dealing with residential property to assess the risks of money laundering and terrorist financing to which its business may be subject. 

Important Notice: The anti-money laundering templates are an EXAMPLE ONLY and are intended to be a starting point to help you implement the requirements set out in the legislation and guidance. You must tailor these templates and documents to reflect the nature, size, and risk profile of your own business. These templates must be read alongside the relevant money laundering regulations and specific HM Revenue & Customs guidance. If you are unsure how to adapt or implement the templates appropriately, professional legal or compliance advice should be sought. This template does not replace your responsibility to ensure you are adequately trained in AML compliance or to consult and adhere to the official guidance issued by HM Revenue and Customs (HMRC) and HM Treasury.

The Regulations

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’), Estate Agents are required to have a written risk assessment in place.  This assessment must be reviewed at least annually. It helps agents understand the specific risks facing their business and ensures appropriate mitigation measures are in place.

HMRC, the supervising authority for Estate Agents, may request a copy of your risk assessment at any time, and you are obliged to provide it.  

Estate agents must collect information in order to prepare their risk assessment. This may include reviewing historic files, consulting with staff, or conducting internal questionnaires. The method and sources of information used must be clearly documented and made available to HMRC upon request. 

Failure to comply with the Regulations may lead to civil penalties or criminal prosecution. Senior managers and nominated officers may also be held personally liable for any breaches.

Suitable Documents

This template can be used in conjunction with the following documents:

Estate Agency Anti-Money Laundering Policy

Customer Identification and Risk Assessment Form for Estate Agency

Agents must consider and document the specific money laundering and terrorist financing risks relevant to their own business model and operations. 

Further guidance

Reference should be made to the following:

Guidance Note: AML for Residential Estate and Lettings Agency

HMRC guidance on the Regulations can be accessed here.  

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