Are You Actually AML Registered? Be Honest With Yourself.

Not "I will be." Not "once I've done a few deals and the cash is coming in." Right now, today - is your business registered with HMRC for anti-money laundering supervision?

That's the question I opened this week's Mini Compliance Over Coffee with, and I'd like you to sit with it for a moment before you answer. Because "I'll sort it once I'm up and running" is exactly the thinking that lands good, well-meaning sourcing agents in a world of bother.

Why this applies to you

If you introduce a buyer and a seller for a property transaction, HMRC considers that estate agency work. It doesn't matter whether you call yourself a sourcing agent, a deal packager, an introducer, or anything else - what matters is what you actually do.

The legal test sits in section 1 of the Estate Agents Act 1979, and it turns on introducing a client to a buyer or a seller. That pulls you squarely under the Money Laundering Regulations 2017, and HMRC's guidance for estate agency businesses has only become clearer on this point.

Registration isn't a nice-to-have. It's a legal requirement, and it has to be done before you start trading — not after your first deal completes.

Registering isn't the finish line

Getting your name on the register is the beginning, not the end. Once you're supervised, HMRC expects you to actually do the work, on every client and every deal:

• Customer due diligence and ID verification

• Establishing source of funds and source of wealth

• A written business-wide risk assessment

• A written policy statement, controls and procedures

• Client-level risk assessments

• Knowing what a Suspicious Activity Report is, and when and how to submit one

And crucially - having those documents in place and using them, not filing them away and forgetting they exist.

The part that costs people money

This isn't theoretical, and it isn't scaremongering. HMRC fined 136 sourcing agents a combined £1.1 million for failing to register - with individual penalties running up to around £26,000. You can download a copy of our research report from last year.

Those are the figures from our own research into the sector, and the overwhelming majority of those fines came down to one thing: trading while unregistered. HMRC can also pursue civil action, and in the most serious cases, criminal action.

For most sourcing agents I know, a £26,000 fine doesn't sting - it ends the business. That's why this is worth ten minutes of your attention today.

Don't trust us check for yourself

This is the NAPSA way, and it always will be. Don't take our word for any of this. Go and look:

Search "HMRC Anti-Money Laundering Supervised Business Register." It's free. It downloads as a spreadsheet. Search it for your own business name. If you're not on it — and if you've never set up a gateway account — you are not registered, and you need to act.

Search HMRC's updated guidance for estate agency businesses. It sets out, in HMRC's own words, who's caught, what's expected, and what "getting it right" actually looks like.

If the register says you're not there, that's not a disaster, it's a to-do list. The worst outcome is the one where you find out from a penalty notice instead of a spreadsheet.

Where NAPSA Can Help You

Knowing you need to register is one thing. Having the risk assessments, policy statements and client procedures HMRC expects, and knowing how to use them properly, is another. That's exactly what NAPSA membership is built to support you with.

👉 Become a NAPSA member: https://education.napsa.org.uk/napsa-membership-property-sourcers

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Frequently Asked Questions

What's the difference between AML training and AML registration?

This is one of the most common questions we get, and it's an important one because they're two separate things, and you need both:

AML registration is signing your business up with HMRC for anti-money laundering supervision. It's an administrative, legal requirement — you must be registered before you trade, and it's what puts you on HMRC's supervised business register.

AML training is learning how to actually meet your obligations day to day: carrying out due diligence properly, recognising red flags, understanding source of funds and source of wealth, and knowing when and how to submit a Suspicious Activity Report. Training the relevant people in your business is also a requirement under the Money Laundering Regulations 2017 in its own right.

Where agents get caught out: being registered doesn't mean you know what to do, and having done a course doesn't put you on the register. Registration without training leaves you exposed the moment HMRC asks how you're applying the rules. Training without registration means you're trading unlawfully.

You need both to be compliant.

We offer dedicated AML training for sourcing agents and deal packagers, so you're not just registered on paper but genuinely equipped to meet the standard HMRC expects: https://education.napsa.org.uk/data-protection-aml-property-sourcers.

Do I need to register if I only introduce deals and don't handle the money?

Yes. Registration is triggered by the nature of the activity - introducing a buyer and a seller for a property transaction - not by whether the funds pass through your hands. If you're sourcing or deal packaging, you're carrying out estate agency work as far as HMRC is concerned.

I've registered with HMRC - does that mean I'm compliant?

Registration is the start, not the finish. Once you're supervised, HMRC expects you to have (and use) a business-wide risk assessment, a written policy statement, controls and procedures, client-level risk assessments, and proper due diligence on every deal - plus an understanding of Suspicious Activity Reports. Getting on the register is step one; doing the work is what keeps you compliant.

My training provider told me I don't need to worry about AML. Is that right?

No, and it's advice that can land you in serious trouble. Any business carrying out estate agency work, which includes property sourcing and deal packaging, has to meet the legal standards. If a course is telling you compliance is optional, treat it as a warning sign about the quality of that training.

How do I check whether I'm registered?

Search "HMRC Anti-Money Laundering Supervised Business Register." It's free, it downloads as a spreadsheet, and you can search it for your own business name. If you're not on it and have never set up a gateway account, you're not registered - and it's time to act.