Short answer: Property sourcers and deal packagers are under the scope of the money laundering regulations, which means you must register with HMRC for anti-money laundering (AML) supervision. It's a legal requirement, and trading without it risks serious penalties.
What is AML supervision?
Certain businesses have to be supervised for money laundering compliance. Estate agency and property work — including sourcing and deal packaging — falls under HMRC's supervision. Registering means HMRC knows you're operating, and expects you to have AML processes, training and checks in place.
Do you need it as a sourcer?
Yes. This is the registration most agents underestimate, and the one HMRC actively enforces. If you source or package deals, you need to be registered and supervised, and you can be fined for trading without it.
What it costs
£740 in your first year, then £440 per year thereafter.
Based on one business premises and one director - add £40 for each additional director.
Paid directly to HMRC.
Do this in the right order
Get your AML training, policies, risk assessments, and controls and procedures in place first, then register. HMRC expects you to already have your anti-money laundering procedures, risk assessment and customer due diligence processes ready; registering without them is doing it backwards, and leaves you exposed if you're ever checked.
You'll also want your redress scheme sorted before this step, as HMRC will ask for those details.
Common mistakes
We talk to thousands of property sourcing and deal packaging agents each year, and we see the recurring issues or mistakes they make:
Not registering at all — the single biggest compliance gap in the sector.
Registering before your AML policies, risk assessments, controls and procedures, and training exist.
Forgetting to renew and having to pay the full first year price.
Missing the extra-director fee.
Get it right
Our AML training and documents courses give you the training, policies, risk assessments, controls and procedures, and customer due diligence framework HMRC expects — so you register from a position of genuine compliance, not just a paid fee. AML training course → and Documents and contracts course →
New to the whole process? Our free setup guide shows every registration in order. Already compliant and want the credibility? NAPSA membership may be all you need.
