Fact sheet: Writing a risk assessment

Fraudsters exploited the vulnerabilities in the property transaction system by stealing a homeowner’s identity and using a fake driving license to set up a bank account in his name to facilitate a sale in 2021. After four years, on 11 March 2025, a County Court finally granted the owner full possession of his home.

Letting agency businesses across the UK need to work to a new framework from 14 May 2025 under the Sanctions and Anti-Money Laundering Act 2018, and it is vital that every agent understands the rules and adjusts working practices and systems accordingly. Through our vast network of members, some confusion has been highlighted around the rules, and we have produced resources to navigate the requirements.

The most recent compliance and registration penalties published by HM Revenue and Customs reveal 144 agents sanctioned between October and December 2023. Most fines were for failing to register at the required time, and the amounts ranged from £1,250 to £52,000. However, the largest fine on the list is for a High Value Dealer ordered to pay £175,701 for multiple failures in carrying out risk assessments, having the correct policies, controls and procedures, appropriate staff training, conducting due diligence, and record keeping.