AML fails - In six months, HMRC fined estate agents £836,000 — most never even registered

HMRC has again shown that failing to register for anti-money laundering (AML) supervision is the single most common reason property agents are fined.

Between 1 April and 30 September 2025,

• HMRC issued 170 penalties to estate agency businesses totalling £835,842.

• Across all sectors it supervises, 369 penalties were issued, totalling £1,881,237.

• Of those, 332 were for businesses trading without the required AML registration.

The official list was published on 29 January 2026.

• Estate agents were the largest single group penalised in that period.

• Accountancy service providers received 134 penalties totalling £513,930.

• Letting agents fall within HMRC’s scope where the relevant thresholds are met.

This is not a new pattern.

• Earlier HMRC publications covering late 2024 and early 2025 also showed estate and letting agency businesses accounting for the bulk of registration-related penalties.

• Industry bodies have repeatedly warned that missing or late registration is an avoidable administrative failure, not a complex due-diligence issue.

• HMRC has said some penalties were reduced where firms came forward voluntarily. It has also been consistent that ignorance of the rules is not a defence.

Trading while unregistered can be a criminal offence and may also attract a civil penalty and public naming.

Those who must register include

• Estate agents, auctioneers carrying out estate agency work, and letting agents where the regulations apply.

• High-value dealers, art market participants and certain other businesses dealing in goods or acting as intermediaries above the €10,000 cash/linked-transaction thresholds also fall under HMRC supervision.

Registration must be in place before relevant activity starts; it must be renewed on time; and firms must notify HMRC of material changes such as a change of Money Laundering Reporting Officer.

Beyond registration, the Money Laundering Regulations require a current,

• Firm-wide written risk assessment, written policies and procedures, staff training, customer due diligence, record-keeping, and

• A nominated officer to report suspicions to the National Crime Agency.

Failures in those areas also attract penalties, though the published lists for this period remain dominated by registration breaches.

A practical point often overlooked:

• HMRC correspondence should go to a generic business email address, not an individual’s inbox, which may become inactive.

The property sector remains a focus because high-value assets and complex ownership structures can be used to move illicit funds. Registration and basic controls are the baseline that HMRC expects before it assesses the quality of due diligence.

• Firms that have not checked their status should do so against the live GOV.UK list and HMRC’s registration guidance rather than relying on secondary summaries.

Primary sources (full URLs):

• Official HMRC published list (1 April–30 September 2025): https://www.gov.uk/government/publications/businesses-not-complying-with-money-laundering-regulations-in-2018-to-2019/businesses-that-have-not-complied-with-the-money-laundering-regulations-2025-to-2026

• Index page for all HMRC non-compliance lists: https://www.gov.uk/government/publications/businesses-not-complying-with-money-laundering-regulations-in-2018-to-2019

• Propertymark summary of the same figures: https://www.propertymark.co.uk/resource/aml-registration-failures-still-the-top-cause-of-painful-agent-fines.html

• The Negotiator report: https://thenegotiator.co.uk/news/regulation-law-news/estate-agents-fined-over-800k-for-aml-breaches/

• Estate Agent Today: https://www.estateagenttoday.co.uk/breaking-news/2026/01/hundreds-of-agents-handed-aml-fines/

• HMRC guidance on who must register and responsibilities: https://www.gov.uk/guidance/money-laundering-regulations-your-responsibilities and https://www.gov.uk/guidance/money-laundering-regulations-who-needs-to-register

The figures above are taken from the official GOV.UK publication and contemporaneous trade reporting of that list. Penalty amounts and firm names on the live GOV.UK page can change if appeals succeed or entries are updated.