TI-UK Report Flags £2.2bn in Suspicious Wealth Linked to UK New-Build Homes-Executive introduction

Transparency International UK has published Concerning Developments: Money laundering risks in new-build property (19 October 2026).

• The insights paper, authored by Steve Goodrich with research by Ben Cowdock and Harry Baines, finds that more than a third of the suspect UK property purchases TI-UK has tracked since 2016 involve new-build dwellings or development sites.

• The report identifies regulatory gaps that leave many developers outside AML obligations, commercial pressures on panel conveyancers, and elevated risks from overseas marketing strategies.

Summary

• Of the 2,000+ UK properties (worth over £12 billion) TI-UK has linked to suspicious wealth since 2016, 708 (worth £2.2 billion) are new-builds or development sites.

• This comprises 630 newly built properties (£1.6 billion) and 78 development titles (£647 million), spread across more than 150 locations and involving over 85 developers.

• Developers selling their own properties are generally not required to be supervised for AML purposes; the national risk assessment estimates that 74% are not registered with an AML supervisor.

• Panel conveyancing arrangements and reliance on pre-sales create incentives that can weaken customer due diligence.

• TI-UK recommends bringing developers into the scope of the Money Laundering Regulations on a risk-based basis, requiring solicitors to report panel membership annually, and requiring annual reporting of work for higher-risk overseas clients.

• The UK government has indicated it will consult on illicit finance risks in the property development sector.

The story

• The UK property market continues to function as a store of value for illicit funds.

  • The National Crime Agency estimates that up to £10 billion could be laundered through UK property each year.

  • TI-UK’s own dataset, built from sanctions lists, court records, investigative journalism, leaks and related sources, has identified more than 2,000 properties acquired with suspicious wealth since 2016.

• Looking systematically at that data, TI-UK found that new-build property accounts for a disproportionately large share.

  • Over a third of the suspect purchases — 708 assets worth £2.2 billion — are either newly built dwellings (630 properties worth £1.6 billion) or development sites (78 titles worth £647 million).

  • These are not concentrated in a single area.

  • They appear in more than 150 locations across England and Scotland, including London, the South East, Birmingham, Leeds and Liverpool, and involve more than 85 developers.

• UK companies and individuals account for the majority by volume (617 assets) and value (£1.2 billion).

  • Offshore entities hold the remainder, with companies incorporated in Jersey, the British Virgin Islands, Guernsey and the Isle of Man owning 72 properties worth £813 million.

  • TI-UK notes that its sample focuses primarily on cases where corruption is a potential predicate offence; the true volume of illicit funds entering the new-build market, including proceeds of organised crime, is almost certainly higher.

Illustrative cases

• A former Bangladeshi land minister

  • Accumulated a UK portfolio worth approximately £170 million (including nearly 300 new-build properties) on a reported annual salary of around £10,000. Assets were frozen by the NCA in 2025.

• In 2021, executives linked to Cambodia’s Prince Group

  • Acquired 27 flats in Embassy Gardens (Battersea) and Centre Point. The group was later sanctioned by the UK and US over human trafficking, fraud and corruption; the properties have been frozen. All purchases were handled by a single firm.

• A Chinese national wanted over illegal gambling has been frozen

  • At Elephant Park (the redevelopment of the former Heygate Estate), early off-plan sales were processed by a single panel solicitor. Nineteen flats linked to a Chinese national wanted over illegal gambling have been frozen.

• An Isle of Man company controlled by an individual

  • Subsequently sanctioned for links to Iranian interests, obtained planning permission for a luxury development in North London.

Why new-builds attract higher risk

Off-plan sales (properties sold before construction is complete) offer several practical advantages to those seeking to place suspicious funds:

• Purchases can be made in bulk, spreading large sums across multiple smaller transactions.

• Interests can be flipped before completion, potentially avoiding stamp duty and keeping names off the Land Registry.

• Developers frequently rely on early sales to fund construction and have no general legal duty to conduct due diligence on buyers.

• Discounted off-plan prices can create opportunities for rapid capital gain.

Three vulnerabilities identified

Regulatory loopholes for developers
Estate agents, banks and solicitors must apply customer due diligence. Developers selling their own stock directly (rather than acting as estate agents) are not automatically within the regulated sector. Separate sales agents and buying agents can further fragment responsibility. The national risk assessment estimates that 74% of developers are not registered with an AML supervisor. Staged payments, reservation fees and third-party contributions add further complexity.

Conflicts of interest in panel conveyancing
Developers commonly maintain panels of preferred conveyancers and direct buyers toward them. In some cases, the developer pays the legal fees. Firms on these panels have a commercial interest in maintaining the relationship and avoiding being seen as obstructive. Hundreds of transactions on a single development can pass through one or two firms. The Competition and Markets Authority has previously raised concerns about the buyer-protection implications of such arrangements; TI-UK argues the same dynamics can weaken financial-crime checks.

High-risk overseas marketing
Mid-to-high-end new-builds are often priced beyond the reach of typical domestic buyers (one-bedroom flats in London frequently start around £400,000). Developers therefore market aggressively overseas through foreign-language websites and sales events. This elevates aggregate risk from higher-corruption jurisdictions where public-domain information for due diligence is limited. Supervisors currently lack systematic data on which firms undertake this work.

Recommendations

TI-UK proposes three practical steps aligned with the government’s forthcoming consultation on widening the Money Laundering Regulations:

• Bring property developers within the scope of AML supervision on a risk-based basis.

• Require solicitors to report annually whether they sit on developer panels.

• Require solicitors to report annually whether they convey for higher-risk overseas clients, enabling supervisors to target limited resources more effectively.

Recent large-scale asset freezes demonstrate that enforcement can recover funds after the event, but TI-UK argues that prevention is more efficient. With the government seeking to increase housing supply, the report stresses that new homes should meet domestic need rather than serve as a store of speculative wealth.

Sources

• Report page: https://www.transparency.org.uk/publications/concerning-developments

• Direct PDF: https://www.transparency.org.uk/sites/default/files/2026-10/Concerning%20Developments.pdf

• Summary article: https://www.transparency.org.uk/news/new-homes-dirty-money-whos-really-buying-britains-new-builds

This is an independent insights paper based on TI-UK’s ongoing research. Figures and case details should be verified against the original publication and official sources before being relied upon in compliance assessments.