HMRC & OFSI fines from 1st Apl 25 to 30th Sept 25
Estate agents and letting agents account for nearly 40% of all money laundering regulation fines. This article explains the enforcement landscape and what it means for your agency.
The Current Enforcement Picture
Analysis of HMRC enforcement data for April to September 2025 reveals that Estate Agency Businesses received 121 penalties totalling £612,597 during just six months. This represents 39% of all businesses fined under the Money Laundering Regulations. No other sector comes close.
Accountants placed second at 24%, with art market participants trailing at 13%.
The average fine for estate agency businesses stood at £5,063, but several agents received penalties exceeding £20,000. The highest single fine was £26,200.
Sector Breakdown of HMRC Fines (April to September 2025)
| Sector | Businesses Fined | Total Fines | Share |
|---|---|---|---|
| Estate Agency Business | 121 | £612,597 | 39% |
| Accountancy Service Provider | 75 | £298,450 | 24% |
| Art Market Participant | 40 | £182,830 | 13% |
| Trust/Company Service Provider | 12 | £93,970 | 4% |
| Money Service Business | 10 | £46,453 | 3% |
| High Value Dealer | 8 | £172,476 | 3% |
Why Agencies Are Being Fined
Many agents do not realise that you do not need to have missed an AML check or facilitated a breach to face enforcement action.
The majority of fines were for Regulation 56 breaches (failure to register for AML supervision at the required time). However, HMRC also issued penalties under Regulations 18, 19, 24, 28, and 33 for failures in risk assessments, policies and controls, staff training, and customer due diligence procedures.
This means HMRC can investigate your agency and fine you for having inadequate systems, even if no actual money laundering occurred. Poor documentation, missing policies, untrained staff, or incomplete risk assessments are all grounds for a fine.
Key takeaway: It is not enough to do the checks. You need to prove you have the systems in place to do them properly.
OFSI Sanctions Reporting for Letting Agents
From 14th May 2025, OFSI sanctions reporting obligations were extended to all letting agents. This adds another layer of compliance requirements for the sector.
Why Banks Are Watching
The continued wave of de-banking affecting letting agents and estate agents is directly linked to AML compliance concerns. Banks conducting due diligence on their commercial clients see an industry that tops the enforcement tables and frequently lacks the systems to demonstrate compliance.
How agentOS and Calmony Help You Stay Compliant
agentOS CRM and Calmony's Client Bank Account integrate compliance tools directly into your letting, sales and banking workflows:
- Automatic screening of every landlord and tenant against the OFSI consolidated sanctions list at onboarding
- AML checks, identity verification, and PEP screening as a single process
- Timestamped and logged checks, creating the audit trail that HMRC and OFSI expect to see
- Daily automatic updates when the sanctions list changes
Not using these features yet? OFSI sanctions screening and AML checks can be enabled in your agentOS settings. Contact your account manager or our support team to switch them on.
Source Data
Analysis based on HMRC published enforcement data for businesses that received penalty notices between 1 April 2025 and 30 September 2025 under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.