How to register for Anti-Money Laundering (AML) supervision

If you are involved in estate agency work, including residential and commercial sales or lettings, you are legally required to register for Anti-Money Laundering (AML) supervision with HMRC before you start trading. Failure to register is a serious offence that can result in heavy financial penalties, public "naming and shaming," or even criminal prosecution.

Who needs to register?

Under the Money Laundering Regulations, "estate agency work" is defined broadly. You must register if you act on instructions from a client to find a buyer or a tenant, or if you introduce a client to a third party looking to buy or rent. This applies to:

• High-street estate agents.
• Online or hybrid estate agents.
• Commercial estate agents.
• Lettings agents (specifically for tenancies with a monthly rent equivalent to €10,000 or more).
• Property auctioneers.

When to register

You must register with HMRC before you carry out any taxable activity. If you are already trading and haven't registered, you must do so immediately. HMRC may apply a penalty for late registration, but coming forward voluntarily is always better than being caught during an inspection.

What you will need before you start

The application is completed online via the HMRC website. To make the process smooth, gather the following information first:

• Government Gateway user ID and password: You’ll need this for your business.
• Business details: Your UTR (Unique Taxpayer Reference), VAT registration number (if applicable), and your Companies House registration number (if you are a Limited Company).
• Officer details: Names, dates of birth, and addresses of all directors, partners, or the sole trader.
• MLRO details: You must appoint a Money Laundering Reporting Officer (MLRO) who will be responsible for your AML compliance.

The registration process

1. Access the HMRC online service: Log in to your Government Gateway account and search for "Anti-Money Laundering Supervision."
2. Complete the application: Provide details about your business structure, the type of property work you do, and the volume of business you expect.
3. Pay the fees: There is a non-refundable application fee (currently £150) and an annual supervision fee for each premises you operate from (currently £300 per premises).
4. Submit the application: Once submitted, HMRC will review your details. They may ask for further information regarding your compliance procedures.

The 'Fit and Proper' test

HMRC must be satisfied that the "relevant persons" in your business (owners, directors, and the MLRO) are honest and reliable. This is known as the Fit and Proper test. As part of this, those individuals will need to pass a DBS (Disclosure and Barring Service) check. HMRC will not approve your registration if any key person has relevant unspent criminal convictions.

Top Tip: Don't just treat this as a tick-box exercise. Once registered, you are expected to have a written "Risk Assessment" and "Policies and Procedures" document in place. HMRC can audit you at any time to see these.

Ongoing requirements

Registration is not a one-off event. You must renew your supervision annually and pay the per-premises fee. You are also required to update HMRC within 30 days if your business details change—for example, if you move offices or appoint a new director.