The May 2025 UK sanctions rule for letting agents: what changed, who enforces it, and how to comply

On 14 May 2025 letting agents were added to the "relevant firms" in UK financial sanctions regulations. A relevant firm must tell OFSI (the Office of Financial Sanctions Implementation, part of HM Treasury) as soon as practicable if, in the course of its business, it knows or has reasonable cause to suspect that a person is a designated person or has breached financial sanctions. For letting agents the duty covers all letting agency work, whatever the rent. OFSI sets this out in its financial sanctions guidance for letting agents.

What changed, and what didn't

• New: the duty to report to OFSI. Where the designated person is your client, the report also says what funds or property you hold for them.
• Not new: the prohibitions. Making funds or economic resources available to a designated person, or dealing with their frozen assets, was already an offence. Letting a property to a sanctioned tenant, or collecting and paying out rent for a sanctioned landlord, can breach them.
• Not a screening rule. Neither the regulations nor OFSI's guidance prescribe a particular check. Screening every tenant and landlord against the UK sanctions list is the practical way to make sure you would know, and a dated record of each screen shows you took the duty seriously.

Who enforces it

OFSI enforces financial sanctions, including the reporting duty, and can impose penalties; serious breaches can be prosecuted. HMRC supervises letting agents under the Money Laundering Regulations 2017, which is a separate regime.

The money-laundering rules are separate

The Money Laundering Regulations 2017 apply to letting agency work only for lets with a monthly rent of £10,000 or more (since 30 June 2026; it was 10,000 euros before), and to all estate agency (sales) work. For those lets you register with HMRC and apply customer due diligence to the landlord and the tenant: identity, anyone owning over 25% of a company, politically exposed person checks, a firm-wide risk assessment, ongoing monitoring, staff training, and records kept for 5 years after the relationship ends. HMRC's guidance for letting agents (AMLG2300) sets out what it expects.

What a good screening record shows

1. Who was screened, when, and against which lists (UK, UN, EU, US).
2. Which version of each list was used, so a later designation doesn't call the check into question.
3. How any possible match was resolved (date of birth, nationality, the listing itself), and who decided.
4. For continuing tenancies, when the parties were screened again.

How Certaby helps

A Certaby Letting transaction screens tenant and landlord against the UK Sanctions List, the UN Security Council list, the EU financial sanctions list and US OFAC in one run (the lists are refreshed daily), follows a corporate landlord's ownership and screens each owner, records the list versions on the certificate, and keeps the certificate for 7 years with a public verify link. PEP and adverse media are a 40p add-on per person. A let is £3.27 (tenant, landlord and the property risk pack), or £4.07 with PEP and adverse media. For continuing tenancies, Certaby monitoring re-screens your watchlist every day and emails you about new possible matches.

To catch up on an existing tenancy book, ask us about bulk screening at /bulk, then run a Letting transaction on every new let.

Source: OFSI: Financial sanctions guidance for letting agents

Last updated 2026-10-02.