What is LSAG-2025 and how does it differ from LSAG-2018?
LSAG-2025 is the 2025 update to the Letting Sector AML Guidance, the HMRC-supervised industry guidance that operationalises MLR-2017 for UK letting agents. It came into force May 2025 alongside the broader sanctions-screening rule. LSAG-2018 was the prior version, published shortly after MLR-2017 came into force.
Key differences in LSAG-2025:
1. Explicit PEP screening expectation. LSAG-2018 mentioned PEP exposure as part of the broader risk-based approach; LSAG-2025 names PEP screening as a default expectation on every let, with the FATF Recommendation 12 categories (current PEP, former-within-12-months, family, close-associate) explicitly listed.
2. Adverse-media check on parties. LSAG-2018 did not require an adverse-media check; LSAG-2025 expects it as a defence-in-depth alongside the sanctions and PEP screen.
3. Beneficial-ownership for corporate landlords. LSAG-2018 was light here; LSAG-2025 explicitly references MLR-2017 reg 5(1)(a) and expects letting agents to walk the PSC tree on corporate landlords, identify UBOs at 25%+ effective stake, and screen each UBO. This is section B of the new guidance.
4. Audit-trail format. LSAG-2025 expects list-version timestamps on the screening evidence so the cert records which version of the OFSI / UN / EU lists were screened against. LSAG-2018 was silent on this, which made post-fact audit fragile.
Certaby's letting-agent suite covers all four expectations and binds the audit trail via a SHA-256 hash printed in the PDF footer plus a public verifier URL the regulator can re-check from the cert alone.
Source: LSAG Guidance
Last updated 2026-05-09.