New Development: Estate Agents’ Perspectives of Anti-Money Laundering Compliance - Four Key Issues in the UK Property Market

Abstract

In recent years, money laundering in the property market has come under scrutiny across the world, attracting significant attention from governments, regulators, policy-makers, NGOs, academics and others. However, there remain gaps in knowledge, which is particularly important given practical difficulties in the implementation of anti-money laundering (AML) obligations. This article offers new insights into such implementation in the context of the UK AML regime and the real estate sector. The authors analyse four important issues relating to the UK AML obligations: customer due diligence (CDD); reporting suspicion; training requirements; and letting (rental) agents. IMPACT: Money laundering in the property market is a significant problem across the globe, yet there is limited understanding of how anti-money laundering (AML) rules are implemented in practice. This article draws on semi-structured interviews with estate agents and compliance officials in the UK to explore this often-overlooked perspective. Interviewees take AML rules seriously, however they are often faced with significant difficulties in practice. This article shows that—in the eyes of interviewees—governments and law enforcement do not understand how the sector operates. Failure to deal with this lack of understanding means that the problem of money laundering via property sales and rentals will continue.

Keywords: money laundering, real estate, UK, practitioners