Do estate agents have to do AML checks on the buyer?
Yes. Under the Money Laundering Regulations 2017, an estate agent enters a business relationship with the buyer, as well as the seller, at the point the seller accepts the buyer's offer (regulation 4(3)). So the buyer needs the same customer due diligence as your seller, and so does a company buying, including the people who own or control it.
HMRC's guidance for estate agency businesses (AMLG2200) says to check the buyer as soon as possible after first contact, before an offer is accepted, and at the latest by the time the business relationship starts. Checking early avoids wasted costs and delays if something turns up.
The checks are the same as for any customer: identify the buyer and verify their identity (regulation 28), find out whether they are a politically exposed person (regulation 35), understand the purpose of the transaction and assess the risk, and check the source of funds and wealth where the risk is high, for example for a PEP or someone from a FATF call for action country (regulation 33). Keep monitoring until completion (regulation 28(11)), and keep the records for five years after the relationship ends, then delete them (AMLG2200).
UK financial sanctions apply on top: estate agents are relevant firms and must report to OFSI if they know or suspect that a buyer is a designated person.
On Certaby, add the buyer to the same Property sale transaction as the seller, and only the new person is charged: £1.39 for the sanctions, PEP and adverse media checks, with the ID and risk records and the first 6 weeks of monitoring at no charge. A company buyer is £4.38, plus 40p for each director and owner the company check finds.
Source: HMRC: estate agency business guidance (AMLG2200)
Last updated 2026-10-04.