Do I need ARLA Propertymark membership to run AML checks legally?
No. The Money Laundering Regulations 2017 (MLR-2017) apply to UK letting agents based on whether the firm meets the in-scope threshold (handling rentals of €10,000 or equivalent per month per property, currently around £8,500 per month), not based on professional body membership. ARLA Propertymark is voluntary; HMRC supervises lettings AML directly under MLR-2017 since 26 June 2017.
What this means in practice: a non-ARLA letting agent handling a £2,000 per month tenancy on a property is in MLR-2017 scope and must register with HMRC for AML supervision, conduct customer due diligence on every let, appoint a Money Laundering Reporting Officer (MLRO), train staff annually, and keep records for 5 years post-relationship-end. ARLA membership adds nothing to the AML duty itself; an ARLA member still has to do all the same checks.
What ARLA membership does add, separately from AML:
1. Client Money Protection. ARLA members must hold ring-fenced client money accounts, an additional Trading Standards-enforced rule under the Tenant Fees Act 2019.
2. Code of Practice + redress scheme. Disputes between the agent and a landlord or tenant route through The Property Ombudsman or Property Redress Scheme; ARLA membership operationalises that.
3. Professional indemnity insurance baseline. ARLA requires members to carry PI cover, providing some protection on negligent advice.
4. Marketing benefit. ARLA membership is a trust signal landlords look for when picking an agent.
5. Continuing Professional Development. ARLA mandates CPD hours including AML training, which helps with the MLR-2017 training-log requirement.
The firms most exposed to HMRC penalty are unsupervised non-ARLA letting agents who do not realise MLR-2017 applies to them. HMRC publishes the list of businesses fined under MLR-2017 on gov.uk; cases where firms failed to register with HMRC for AML supervision at all are the most common, with failure-to-register fines typically starting in the low thousands and exceeding £25,000 for larger firms.
For a firm deciding whether to join ARLA, the AML question is separate. The right answer for AML is: register with HMRC under MLR-2017, appoint an MLRO (the owner can self-appoint at sole-trader or small-firm scale per reg 21), and run a defensible client check on every let. ARLA membership is a separate strategic question about insurance, redress, and marketing positioning.
Certaby's letting-agent suite produces the per-let audit cert HMRC asks for at inspection time, regardless of ARLA status. A £4.95 PAYG check with a signed PDF and a 7-year verify URL covers the MLR-2017 reg 28 customer-due-diligence requirement and the reg 40 record-keeping requirement in one transaction. The firms most at risk (small, non-ARLA, manual-process) get the biggest practical benefit from a no-contract PAYG tool.
Source: HMRC MLR-2017 Guidance
Last updated 2026-05-19.