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Agents facing increased AML fines ‘by accident’ - warning

Most agents are falling foul of anti-money laundering (AML) rules by accident but the sector could face more compliance-related fines by the end of the year, according to new predictions.

Forecasts by AML platform Credas Technologies claim the total value of AML fines in the agency sector for the 2022-2023 period, which runs from 1 April 2022 to 31 March 2023, will be £177,570.

Credas highlights that this pales in comparison to the £772,618 worth of fines handed out to estate agencies in 2021/2022 and is almost £850,000 less than the annual fines peak of 2019/2020 when agents were forced to pay almost £1.1m. 


The platform is also forecasting that the volume of AML fines issued to the estate agency sector will drop.

Therefore, while the average fine issued may be set to increase, it is expected that there will be fewer fines overall.

Research by Credas, based on HMRC data, revealed that the estate agency sector is driving up the value of AML fines.

Across five major industries - accountancy services, estate agency, money services, trust or company services and high value dealers - the average AML fine has increased in size by 19% in the past year, rising from an average £75,078 in 2020/2021 to £89,372 in 2021/2022. 

This average increase has been driven entirely by the estate agency industry, with the average fine up by 63.7%, from £3,577 to £5,853.

Of the four remaining industries, three have seen the average AML fine shrink in the past year

However, the severity of AML fines issued within the estate agency sector is the second-lowest across all industries.

Tim Barnett, chief executive of Credas Technologies, said: “On the face of it, an increase in the average AML fine issued to estate agents may seem like a backwards step, but when taken in context of where the sector was, we’re certainly moving in the right direction. 

“While the average fee may have increased, the total sum handed down in fines and the sheer volume of these fines is expected to fall substantially come the end of the 2022/23 financial year. At the same time, the severity of fines issued to the estate agency sector is extremely low when compared to many other sectors.

“This suggests that those who do fall foul of AML sanctions are doing so accidently and due to a lack of awareness, rather than as the result of any intended illicit activities. 

“In fact, the nation’s estate agents deserve praise for the manner and speed in which they have managed to get their AML ducks in a row at a time when the market has still been booming and they’ve been busier than ever, processing a record number of transactions and dealing with the practical fallout of a global pandemic.”

It comes as AML platform Thirdfort has called on agents to see these checks as an ongoing need rather than a one-off action.

Harriet Holmes, AML services manager for Thirdfort, said: “Throughout a relationship, estate agents may find a client’s circumstances change, impacting that client’s fraud and money laundering risk profile.

“For instance, someone may become a politically exposed person by standing for election, by way of marriage, or a government may have sanctioned that individual.

“Alternatively, if their client owns a business, there may be a change in beneficial ownership or control in that company, or they may have expanded into other countries or sectors.”

She said these kinds of changes in circumstance mean estate agents must review and renew due diligence and risk assessments, adding: “Without some form of ongoing monitoring, it is easy for estate agents to neglect these reviews and fall foul of regulations.”

Table shows annual change (%) in anti-money laundering (AML) average fines issued to five major industries  
    Business type Est average penalty 2020 to 2021 Est average penalty 2021 to 2022 Annual change - average penalty value %  
    Accountancy Service Providers £5,781 £3,547 -38.7%  
    Estate Agency Businesses £3,577 £5,853 63.7%  
    Money Service Businesses £237,418 £167,457 -29.5%  
    Trust or Company Service Providers - £7,679 -  
    High Value Dealers £58,586 £18,050 -69.2%  
    Total Penalty Values £75,078 £89,372 19.0%
  • Oliver Meddick

    Such as great article

    The estate agency sector must look to adopt technological solutions to both protect themselves and their clients.

    The Solution must be both user friendly and add value to both the agent and client.

    I am happy to speak to agents to guide them on the protection needed to standout in a tightening market

  • Proper Estate Agent

    Yet another plug article.
    The Government should be paying agents to do AML for them.
    No mention of conveyancers who actually transact the money of course; who half the time don't even bother with buyer ID until nearing exchange ime!

  • icon

    AML articles are always written by AML solution providers. How odd.

  • icon

    So agents pay the government £600 per year per branch for the privilege of doing their job for them and they also pay an AML provider per individual check. I absolutely agree that the government should be incentivising agents to do this and not fining them. This all pales into insignificance when you consider the tens of thousands of illegal immigrants that are being allowed to freely enter the UK and the government have no idea of their intentions. I believe the Albanian drug gangs happily laundering money through their Turkish barber shops and hand car washes with no checks being made.


    David, I agree with the first part of your comment, but that's some generalisation you have made in the second half. I trust you are using a pseudonym, as you made a career-crushing comment. Shall we now call all estate agents 'dodgy', or all bankers 'crooks', and football fans 'hooligans? You get the gist.


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