ECSH55125 | General risks in the letting agent business sector

Rental land and properties above the £10,000 threshold are considered attractive for laundering illicit funds due to their high value. Letting agent businesses (LABs) handle client money, including fees, deposits and rent, which brings increased risks of money laundering. The volume of funds that can be laundered through rental properties varies greatly across property location and type.

Common risks throughout the sector may present as, but are not limited to, the following:

• A third party, apparently unconnected with the customer pays rent or fees.

• Rental or large deposit payments paid for fully in cash or a foreign currency.

• The tenant will not disclose the source of the funds where required.

• The landlord will not disclose their source of wealth where required.

• The tenant does not appear to have the lifestyle or income that matches the amount needed to cover the letting value.

• Complex corporate structures are being employed for no apparent reason.

• Unusual source of funds, such as virtual currencies or funds from high-risk jurisdiction

• A request is made for the LAB to hold a large amount of customer funds, which would seem unusual.

• Full payment, or a large payment, for a rental is made up front.

• Multiple lets are being taken up for no apparent reason.

• Where it is known that a tenant is immediately sub-letting the land, and this would be considered unusual by the LAB.

• A non-UK resident using intermediaries where it makes no commercial sense.

Further information on risks

More information regarding risks can be found within:

HMRC’s “Risk Assessment of Letting Agent Businesses: letting agency businesses” document on gov.uk.

National Risk Assessment 2025.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)