Picture a high-street branch handling a £3m sales instruction where the buyer routes funds through two offshore companies. The negotiator clocks something odd, but is it odd enough to file? That small judgement call sits at the heart of why the UK property sector keeps missing suspicious activity—and why Propertymark has gone public about it.
The trade body is calling for "clearer, simpler and more practical guidance" on anti-money laundering rules. It says existing rules are confusing, inconsistent with financial sanctions, and hard to apply during live transactions.
What Propertymark wants
The trade body has a clear ask: practical guidance, not more statutes. Agents need templates, worked scenarios and decision trees they can run through while a deal is live, not another layer of regulation.
It also wants the £10,000-a-month rent threshold scrapped so all letting agents sit inside the Money Laundering Regulations. Currently, only those handling high-value lets fall in scope—a gap Propertymark says criminals exploit.
The National Crime Agency has flagged that suspicious activity reports from property remain low, despite an estimated £6.7 billion of UK property being bought with suspect wealth between 2016 and 2022.
Who should care
Estate and letting agents** – If the threshold is scrapped, every letting-only firm will need AML registration, an MLRO and internal controls. Smaller agencies bear the biggest compliance burden.
Investors and brokers** – Lenders increasingly ask for evidence of an agency's filing culture before referring deals. Pension funds and family offices buying through UK vehicles now request AML manuals and audit dates. Weak compliance history affects deal flow.
The market itself** – Dirty money distorts prices. The £6.7bn estimate sits in public domain, shaping how counterparties price integrity risk. A cleaner market commands fewer discounts.
AML checklist for investors
Before instructing any UK agent, ask for:
- Their HMRC AML registration certificate
- The MLRO's name and deputy
- Their suspicious activity reporting log (12-month window)
- Staff training records for AML awareness
- The internal escalation process for suspicious transactions
Unable to produce these quickly? That is information in itself.
Why this matters
The interesting thing about Propertymark's position is what it is not saying. It is not arguing for less enforcement—it is arguing for better execution. That matters.
Winners if guidance improves: small and mid-sized agencies, which currently absorb the cost of getting it wrong. Losers if it does not: the same firms, plus the wider market, which keeps carrying the discount that comes with a "London laundromat" perception.
The trade-off is real. Heavy-handed AML pushes transactions offshore or into unregulated channels. Light-touch AML invites blunt instruments from the FCA and NCA. The middle path is sector-specific guidance that reflects how property transactions actually close—with named clients, escrow timelines and a mix of regulated and unregulated participants.
What to watch next
If the £10,000 rent threshold is removed, expect a wave of AML registrations from letting-only firms, with a short-term squeeze on instruction throughput as those agencies get compliant. Watch for any NCA update on suspicious activity report volumes: a genuine rise in filings would signal that guidance, not legislation, was the missing piece.
Key takeaways
- Propertymark wants sector-specific AML guidance with worked examples, not new statutes.
- Low suspicious activity report volumes from property are a known weakness.
- Letting agents handling rent of £10,000+ per month are currently in scope; the threshold could disappear.
- Investors should ask agents for AML registration, MLRO details and training records before instructing.
- Expect compliance costs to rise for small agencies if the threshold is scrapped, with a short-term slowdown in high-end lettings.
Frequently asked questions
What is Propertymark asking the government to change about AML rules?
Propertymark wants clearer, simpler guidance with real-life examples, and the removal of the £10,000-a-month rent threshold so all letting agents sit inside the Money Laundering Regulations.
How much UK property is estimated to have been bought with suspect wealth?
The National Crime Agency has cited an estimated £6.7 billion of UK property bought between 2016 and 2022 using wealth suspected to come from questionable sources.
Do all letting agents currently have to register with HMRC for AML supervision?
No. Only letting agents handling high-value transactions, currently rent of £10,000 or more per month, are in scope. Sales agents are covered regardless.
What is an MLRO and what do they do?
An MLRO, or Money Laundering Reporting Officer, is the nominated person in a regulated agency who decides whether an internal suspicion report should be escalated to the National Crime Agency as a Suspicious Activity Report.
Why do suspicious activity reports from property agents stay low?
Propertymark and the NCA have both pointed to unclear guidance and inconsistent rules as reasons agents under-report. Training gaps and a lack of practical examples compound the problem.
