1. When customer due diligence applies

• The business must apply customer due diligence when it establishes a business relationship, when it suspects money laundering or terrorist financing, and when it doubts information obtained earlier for identification or verification (reg 27(1)).

• Estate agency work has no money threshold. A property transaction always has an element of duration, so it is a business relationship, not an occasional transaction (HMRC AMLG2200), and an estate agent is treated as entering into a business relationship with a purchaser (as well as with a seller) when the purchaser’s offer is accepted by the seller (reg 4(3)).
• HMRC treats property worth £5 million or more in London and the South East, or £1 million or more elsewhere in the UK, as super-prime (HMRC AMLG3200).

The rest of the full document

• 2. Who is checked
• 3. When the checks are done
• 4. What the business checks today
• 5. Enhanced due diligence and PEPs
• 6. Ongoing monitoring and source of funds
• 7. If the checks cannot be completed
• 8. Records
• Sources