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Why does Griffin Bank charge verification fees when other banks don’t?

Griffin uses specialist data sources and tools to meet its obligations under the Money Laundering Regulations 2017 (MLRs). This proactive compliance approach protects your business and your landlords from regulatory risk.

The short answer

All UK banks must comply with the MLRs 2017. These regulations require banks to verify account holders and monitor for financial crime. Griffin uses specialist third party verification tools to do this, and the cost is passed through as a verification fee.

Why don’t other banks charge for the same checks?

Banks handle compliance differently. Some absorb costs into general fees or cross subsidise from other revenue. Others take a lighter touch approach. Griffin has deliberately invested heavily in risk infrastructure from the outset. This is a strategic decision, not an arbitrary charge.

Are other banks breaking the law?

Not necessarily. The MLRs set requirements all banks must meet, but the methods vary. However, banks that take a lighter touch approach to AML compliance are exposed to significant enforcement risk. Recent high profile FCA fines demonstrate the consequences:

 

Bank

Fine

Year

Reason

NatWest

£264.8m

2021

£365m in deposits went unmonitored including £264m in cash. Criminal charges brought.

Santander UK

£107.8m

2022

Serious AML control gaps over nearly five years. £298m in suspicious funds passed through.

Metro Bank

£16.7m

2024

Failed to monitor 60m transactions worth £51bn due to flawed automated systems over four years.

Barclays

£42m

2025

Failed to monitor high risk clients, allowing criminal funds through the system.

Lloyds Banking Group

Under investigation

2024

FCA opened investigation into AML controls framework. Investigation disclosed in annual report.

 

The FCA has made clear there will be no let up in targeting AML failures. When banks receive fines of this scale, their typical response is to de-risk by closing accounts in sectors they consider higher risk. Letting and estate agents are increasingly affected by this, with high street banks closing client accounts or refusing to open new ones, stating that client accounts are “outside of our risk appetite.”

This is where Griffin and Calmony’s approach provides a genuine advantage. Because Griffin has invested in proper compliance infrastructure from day one, it accepts and manages the risk profile of property agents rather than retreating from it. This means a higher probability of keeping your client account open and operational, rather than facing unexpected closure.

What checks are involved?

Standard UK individual landlords go through a straightforward ID&V process. Overseas landlords and those with complex ownership structures (e.g. limited companies) require enhanced due diligence, including:

  • International identity verification using specialist data sources
  • Company ownership checks to identify beneficial owners
  • Sanctions and Politically Exposed Persons (PEP) screening
  • Ongoing monitoring obligations under the MLRs

Why is there an annual re-verification fee?

Regulation 28(11) of the MLRs 2017 requires banks to carry out ongoing monitoring of all business relationships, including keeping Customer Due Dilegence records up to date. For higher risk relationships such as overseas and complex ownership landlords, enhanced monitoring with more frequent reviews is required.

This is no different to any business account holder. If you hold a business bank account, your bank asks you to re-verify your information annually, which is then re-checked. The same principle applies here. Company structures change, directors are appointed, shareholders change, entities move jurisdiction. The annual check ensures everything remains current and compliant.

How the fee works:

  • Initial verification: one off fee when first verified
  • Annual re-verification: same fee applies each year if the payee is active
  • Active payee: has received or paid funds within the last six months
  • Inactive payees: no fee if no transactions in over six months

Note: a company that passed a standard check initially may be reclassified as complex ownership at re-verification if the ownership structure has changed (e.g. new overseas shareholders or directors).

Why does Griffin take this approach?

Griffin’s CEO David Jarvis has written about the concept of “regulatory debt” – what happens when financial institutions under invest in compliance. While a lighter touch seems cheaper short term, it risks frozen operations, FCA fines, and sanctions against leadership. You can read the full article here:

Regulatory Debt – Griffin Blog

Griffin’s position is that sustainable banking partnerships require proper compliance investment from day one, protecting both Calmony’s property agent customers and the landlords whose funds are held in client accounts.

What does this mean for your landlords?

The verification fee ensures landlord identities are properly checked in line with UK law. This protects them by ensuring the bank holding their rental income operates within a robust compliance framework, and protects your agency from regulatory risk that could disrupt property management and payments.

For overseas and complex ownership landlords, annual re-verification keeps records current and reduces the risk of account freezes or payment disruptions that occur when compliance issues are discovered late.

Crucially, because Griffin properly manages regulatory risk rather than avoiding it, your agent’s client accounts are far less likely to be suddenly closed as part of a bank de-risking exercise.

Key legislation

  • MLRs 2017 (as amended) – customer due diligence, enhanced due diligence, and ongoing monitoring (Reg 28(11))
  • Sanctions and Anti Money Laundering Act 2018 – UK sanctions framework
  • OFSI Financial Sanctions (May 2025) – letting agents must screen landlords and tenants against the UK sanctions list

 

Further reading

Griffin Blog: Regulatory Debt by David Jarvis https://griffin.com/blog/regulatory-debt

GOV.UK: Financial sanctions guidance for letting agents gov.uk/financial-sanctions-guidance-for-letting-agents

GOV.UK: Money laundering supervision for letting agency businesses gov.uk/money-laundering-supervision-for-letting-agency-businesses

Legislation.gov.uk: MLR 2017 Part 3 – Customer Due Diligence legislation.gov.uk/uksi/2017/692/part/3

Banks are closing their doors to letting agents – Letting Agent Today lettingagenttoday.co.uk

This article is for informational purposes only and does not constitute legal advice.