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HMRC highlights money-laundering breaches and penalties

Wednesday 18 September 2019

HMRC’s list of business penalised for breaches of money laundering regulations has been updated. The businesses, which include financial services companies and estate agents, are listed on the website detailing breaches that occurred in the 2019-2020 tax year.

HMRC has a duty to publish details of businesses that do not comply with the regulations. The list details compliance and registration penalties, prohibitions on management, and minor penalties.
Five businesses incurred penalties for breaches of money-laundering regulations. Compliance issues included:

  • failures in carrying out a risk assessment
  • failures in having the correct policies controls and procedures
  • lack of staff training
  • lack of customer due diligence
  • record-keeping failures

The highest penalty amount to one company was more than £7million, and three businesses incurred fines of £500 for failing to provide requested documentation. One person was prohibited temporarily from holding any office or management role.

Online estate agency emoov was fined £3,721 for failures in policy, procedures and staff diligence, though it is important to note that the company went into administration in December 2018, and the company that now owns the emoov name was not involved in the breaches.

It is imperative that agents comply with their Anti Money Laundering (AML) obligations. It is a legal requirement for all relevant employees to receive anti-money laundering training so they can understand and implement the correct procedures in line with the latest legislation. 

Steps agents must take include:

  • Develop a written, up-to-date risk assessment of the location you operate in, the customers you have and the value of transactions you are undertaking
  • Prepare a written policy statement and procedures to show how your business will manage the risks of money laundering
  • Train and support staff to understand and implement these policies
  • Ensure that procedures and audit processes are applied to all branches in or outside the UK
  • Appoint a nominated officer (Money Laundering Reporting Officer - MLRO) to report suspicious activity to the National Crime Agency (NCA)
  • Ensure suitable control measures are in place. 

How Propertymark can help

This list is not exhaustive, and many Propertymark members have sought help in becoming AML – compliant. To help agents understand and meet their obligations, Propertymark has developed a series of resources on AML, including AML Health Checks, training courses and on-demand learning, and other member resources.


NAEA Propertymark is running a webinar on 22 October where Jerry Walters, Chief Executive of Financial Crime Services, will outline how to undertake effective anti-money laundering customer due diligence.