Do estate agents have to report sanctions matches to OFSI?
Yes. Under UK financial sanctions, a firm or sole practitioner that carries out estate agency work is a "relevant firm". It must report to OFSI (the Office of Financial Sanctions Implementation, part of HM Treasury) as soon as practicable if it knows or has reasonable cause to suspect that a person is a designated person or has breached the sanctions. OFSI's guidance says a relevant firm that fails to report commits an offence, which may lead to a criminal prosecution or a monetary penalty.
The duty applies on every sale, whatever the price, and covers buyers, sellers and anyone else you deal with. A company counts as sanctioned too if a designated person holds more than 50% of its shares or voting rights, or otherwise controls it, so for a company buyer or seller the people who own and run it matter as much as the company.
The rules don't prescribe how you find out. Screening each buyer and seller against the UK Sanctions List, and for international clients the UN, EU and US lists, is the practical way to make sure you would know, and a dated record of each check shows the duty was taken seriously. The money-laundering rules sit alongside and ask for customer due diligence and PEP checks on the same people.
If a match is confirmed, don't deal with the person's money or property, report it to OFSI, and where you suspect money laundering, make a report to the National Crime Agency as well.
Certaby screens against the UK, UN, EU and US (OFAC) lists, refreshed daily: 99p a person, or £1.39 with PEP and adverse media. In a Property sale everyone named is then watched daily until completion.
Source: OFSI: UK financial sanctions general guidance
Last updated 2026-10-04.