ECSH53150 - What would you expect to see on a compliance intervention at an estate agency business
Source: gov.uk (2025-04-22)


An estate agency business (EAB) can range from a traditional high street estate agent with a few staff, to online only EABs, with no dedicated premises for customers, to large corporations with multiple offices and thousands of staff. EABs are located all over the UK.

The EAB sector is relatively diverse, and can differ depending on the sub-sector that the EAB is trading in.

The operating times for EABs vary based on the business in question. Most operate 9-5 on weekdays, but many residential EABs open on the weekend.

How are EAB customers engaged and communicated with?

EAB customers can be geographically spread due to the nature of the property market, the rise of online only EABs and the use of property portals and search engines.

The vast majority of initial contact between EABs and their customers are done online for property buyers, usually through the EAB’s website or through a property portal, or by phone.

Traditional high street estate agents will still receive engagement by customers visiting and passing by their physical premises.

Sellers are most likely to use EABs local to them, online EABs that usually have lower prices, or niche EABs that deal exclusively with their property type.

It is important to note that different types of EAB also have an impact on how customers are engaged with.

Where do EAB customers live?

EAB customers range dramatically, including first time buyers, families, wealthy overseas individuals, property investors and commercial customer. Their location differs due to the nature of property market – customers will not always be local to the EAB and often will be from overseas.

Some EABs are niche and only cater to specific sub-sectors of the market – such as those specialising in high end “super-prime” property. Their customers are more likely to live in more expensive areas – such as central London, Cheshire and parts of the south coast.

What type of records are kept?

It is standard practice for EABs to maintain a file for each of their customers which will record basic information such as names, addresses and phone numbers.

Records of customer due diligence (CDD) measures applied to the buyer and seller at the outset of the business relationship, including the EAB’s risk assessment of that customer and any ongoing monitoring records, must be held, either alongside or separate to these working papers.

MLR 2017 do not specify the medium in which records should be kept, but they must be readily retrievable. It is essential that an EAB has an efficient record keeping process in place, as you will need to review business records to firstly understand how the business operates and what paperwork is created during a sale or purchase.

What types of systems and software do EABs use?

Software is available that can be used to support tasks an EAB may undertake, for example to store and manage records, customer relationship management systems (CRMs) etc. There are also systems which are marketed as aiding business’ compliance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) obligations.

Any business using computerised records will typically have a backup process, so that records can be retrieved in the event of a data loss. This may be cloud based or the EAB may have physical hard drives. The use of any software/system which aids an EAB with their CDD, record keeping and/or any other of their obligations under the MLRs should be fully understood by the EAB, including its limitations, and the EAB should be able to explain this to a compliance officer on a visit.

Any failures or limitations of the systems or software an EAB uses to assist them in complying with the MLRs, remain the responsibility of the EAB.

Use of systems and software depend on the EAB in question. Some EABs will still use physical and paper files.

Third Party Identity Providers

There are many third-party identity providers that operate with the EAB market that undertake CDD checks. What they provide differs depending on what identity provider they use and what level of service they pay for. Some will conduct basic background checks, whereas others may only check against sanctions. Most will provide a report, which could show a colour risk score or ticks and crosses.

It is important to note that the business is responsible for having the relevant CDD paperwork, not the identity provider. Any report they provide must be examined by the business, who will need to decide if any further action needs to be taken to ensure they have the met the CDD requirements under the regulations.

Additional information regarding EABs and EAB risk and compliance visits is contained in section ECSH53175 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh53175) and compliments this page of the handbook.