Can I be the MLRO for my own letting agency? What if I am a sole trader?
Yes. Under MLR-2017 reg 21, a sole trader running a letting agency is automatically the Money Laundering Reporting Officer (MLRO) of their own firm; no separate appointment is needed. For 2-10 staff firms, the owner or a named director takes the role. There is no formal qualification required, but the MLRO must be a 'person of appropriate seniority' with the authority to make compliance decisions and access to the resources needed to do the job.
What the MLRO must actually do in a letting firm:
1. Sign off the firm's AML policy and the firm-wide risk assessment under reg 18. This is the document HMRC asks for first at inspection. It should describe the firm's risk profile (geographies, customer types, transaction types), the controls in place, and the review cadence.
2. Receive internal suspicion reports from staff. Any staff member who suspects money laundering raises it internally to the MLRO; the MLRO decides whether it crosses the threshold for an external report.
3. File Suspicious Activity Reports (SARs) to the National Crime Agency's UK Financial Intelligence Unit (UKFIU). SARs are filed via the SAR Online portal. The MLRO is the named filer.
4. Maintain the training log. Every member of staff who interacts with customers must receive AML training annually; the log records who was trained, when, and on what content. This is regularly missed at small firms and a common HMRC penalty reason.
5. Respond to HMRC inspections. The MLRO is the firm's named contact for HMRC AML supervision and answers questions on the firm's records during an inspection visit.
For a sole trader the practical reality is that one person does all of these jobs in addition to running the firm. The legal scaffolding works the same as for a 10-person firm; the workload is lower because there are fewer staff to train and fewer customers to screen.
The MLRO appointment must be in writing. For sole traders, a short signed memo stating 'I appoint myself as MLRO under MLR-2017 reg 21, effective DD/MM/YYYY' kept in the firm file is enough. For small firms, the same memo signed by the partners or directors. HMRC inspectors look for this document specifically; missing it is the second-most-common reason for penalty after failure-to-register.
The audit trail per check is the other piece. MLR-2017 reg 28(11) requires firms to keep records of customer due diligence measures applied; reg 40 requires retention for 5 years post-relationship-end. Certaby's letting-agent suite produces a signed PDF cert with a SHA-256 hash plus a public verify URL that resolves for 7 years, covering both rules in one transaction. A sole-trader MLRO running the suite at £4.95 per let has the per-check evidence and the retention requirement satisfied without manual record-keeping.
Source: HMRC MLR-2017 Guidance
Last updated 2026-05-19.