AML compliance for letting agents in 2026: a practical guide

We first wrote about Anti Money Laundering checks back in 2018, shortly after the Money Laundering Regulations 2017 came into force. At the time, AML checks were optional for most letting agents - the regulations applied to estate agency work (buying and selling) but the government had decided not to extend them to lettings activity. Eight years later, that position hasn't technically changed, but the practical reality has shifted quite a bit.

Here's why we think AML is worth paying attention to, even if it's not mandatory for your lettings business.

The current legal position

Under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended), estate agents who carry out property transactions - sales and purchases - must carry out customer due diligence. This includes verifying the identity of clients and checking them against sanctions lists.

Lettings-only activity is not currently within scope. However, if your agency handles both sales and lettings (as many do), the AML regulations apply to your business as a whole. And if you manage property on behalf of landlords who are themselves investors or companies, the lines can get blurry.

Why agents are choosing to do AML checks anyway

We've seen a marked increase in the number of our customers opting for AML screening as part of their standard referencing package. When we ask them why, we tend to hear similar reasons:

• It's cheap insurance. An AML check through our platform costs very little on top of a standard reference. If it flags something, you've avoided a potentially serious problem. If it doesn't, you've lost nothing.
• Landlords are asking for it. Professional landlords and portfolio investors are increasingly aware of the reputational and legal risks of letting to someone involved in financial crime. They want to know that proper due diligence has been done.
• OFSI enforcement is increasing. The Office of Financial Sanctions Implementation has stepped up its activity in recent years. While most of their enforcement actions target financial services firms, there's a growing expectation that all businesses should be screening against sanctions lists. A letting agent who discovers - after the fact - that they let a property to a sanctioned individual is going to have a very uncomfortable conversation with regulators.
• It's heading that way anyway. There's been persistent talk of extending AML regulations to cover lettings. Whether it happens this year, next year, or in five years, nobody knows. But agents who've already built AML checks into their process won't need to scramble when the rules change.

What our AML checks cover

Through our partnership with Equifax, our AML screening cross-references applicants against:

• UK and international financial sanctions lists (HM Treasury, EU, UN, OFAC)
• Politically Exposed Persons (PEP) databases
• Adverse media screening
• Law enforcement watchlists

The check is fully automated and returns results within seconds as part of the standard referencing process. There's nothing for the agent to do manually - we handle the screening and flag any matches in the reference report.

GDPR considerations

If you're running AML checks, you need to make sure your privacy notices and data processing agreements reflect this. The applicant needs to be informed that their data will be checked against sanctions and PEP databases, and you need a lawful basis for processing that data. For most agents, this will be legitimate interests - the prevention of financial crime.

Our application forms include the necessary consent wording, so if you're using Vorensys for your AML checks, this is already covered.

How to enable it

AML screening is available on all Vorensys accounts. You can either enable it as a default for all applications (so every reference automatically includes an AML check) or select it on a case-by-case basis. To switch it on, just call us on 01630 318181 or mention it during your next reference submission.

Given the minimal cost and the potential consequences of not checking, our honest recommendation is to make it standard. But it's entirely your call.