Cutting red tape: Anti-Money Laundering & Terrorist Financing Review

Thursday 22 October 2015

The NAEA has responded to the Government’s Review of the impact on business of the current anti-money laundering and terrorist finance regime.

The Government’s clear policy is that businesses’ (including estate agents) approach to money laundering and terrorist financing should be risk-based.

This means that estate agents are expected to form their own judgement of where the risks fall in a given case and how best to comply with the relevant legislation and sectoral guidance.   

The Review (scroll to the bottom of the page for a detailed overview) which is part of the wider Cutting Red Tape programme is seeking evidence in relation to the role of all supervisors in the implementation of the current Money Laundering Regulations (2007) and the ineffective requirements imposed on business through legislation or its implementation.   

Issues concerning the regulation of systemic financial risk fall outside the scope of the review. 

Following a roadshow of masterclass events around the country about the Money Laundering Regulations, NAEA’s response to the Government Review has concentrated on the following areas:

  • How we regulate NAEA members through NFoPP Regulation
  • What we do to educate and inform members about relevant legislation
  • How much it costs estate agents to register with HMRC
  • Problems with due diligence checks and sub-agency relationships
  • Identifying beneficial owners but no requirement for the owners of property to be publicly available in the Land Registry
  • Protecting client money and banks unilaterally changing the status of accounts
  • The administration around Suspicious Activity Reports
  • Estate agency staff training, awareness and administration associated with the legislation


Evidence gathered by the review will be shared with Government Departments, authorities and regulators.

Relevant findings will be fed into the Government’s analysis and forthcoming consultations on the implementation of the 4th EU Money Laundering Directive plus the Regulation on information accompanying transfer of funds.