The property sector remains under scrutiny, and Suspicious Activity Reports (SARs) are one of the main ways professionals can help stop criminals from using the UK housing market to clean illicit money.
Agents need consistent rules and better support
Propertymark has long argued that a lack of regulation leaves the sector exposed. Currently, anyone can set up as an estate or letting agent — a vulnerability that criminal networks can exploit. That is why we have welcomed proposals from the UK Government to introduce a Code of Practice for property agents as part of their home-buying and selling reforms. We continue to support mandatory qualifications to ensure every sales and letting agent is competent, licensed, and accountable.
We have previously drawn attention to the lack of sector-specific guidance and critical inconsistencies between AML regulations and financial sanctions, which create confusion and lead to uneven compliance. We’ve also highlighted the complexity faced by multi-disciplinary property businesses that offer both sales and lettings. Our position is that property agents need clearer, simpler and more practical guidance, including real-life examples, because many agents find the current process difficult to apply in fast-moving transactions.
Support for Propertymark members
It is a legal requirement for relevant property professionals to receive AML training and stay up to date with the rules. To aid compliance, Propertymark offers courses covering AML essentials, advanced training for Money Laundering Reporting Officers (MLROs), practical compliance, refresher learning, and eLearning introductions.
Our dedicated AML Knowledge Hub page offers quick access to training options, news and updates, fact sheets, webinars, best practice guidance, and links to relevant UK Government resources to help members meet their obligations.
What is a SAR?
When a person or business knows or suspects that someone may be involved in money laundering or terrorist financing, they should submit a SAR to the UK Financial Intelligence Unit, which is part of the NCA. SARs alert law enforcement to potential money laundering or terrorist financing, but they are not crime reports and do not replace the need to report a crime to the police or another relevant authority where appropriate.
In the property sector, a SAR may relate to concerns about the source of funds, the identity of the buyer, seller, landlord, or tenant, the use of complex ownership structures, unusual payment arrangements, or activity that does not make commercial sense.
Reducing economic crime in the property sector
Purchasing property in the UK is a common method that can be used by serious organised criminals to launder the proceeds of criminal activity. This position paper includes recommendations that the UK Government should include in future legislation as well as other plans and reforms to reduce economic crime.
Agents’ legal responsibilities
If an agency is covered by the Money Laundering Regulations (MLRs), it must have systems in place to identify and report suspicious activity.
All estate agency businesses are required to register with HMRC for anti-money laundering supervision. Letting agency businesses are in scope where they carry out high-value transactions, currently where rent is £10,000 or more per month. Propertymark has called for the threshold to be removed so all letting agents are brought within the MLRs, because criminals can also exploit this area.
Businesses covered by the regulations must carry out customer due diligence, assess the risks of their business and put in place internal controls and monitoring systems, including a nominated officer or MLRO and a deputy. In some cases, agents must also identify the beneficial owner behind the customer or transaction.
Where an employee becomes aware of a suspicious transaction or activity, they must report it internally to the MLRO, who is responsible for deciding whether to submit a SAR to the NCA.
Agents should make sure their teams understand the internal reporting route, know who the MLRO and deputy MLRO are, understand the warning signs of suspicious activity, and keep records of training, decisions and reports. A SAR should never be treated as an administrative afterthought. It is a key legal duty and an important protection for the business, the client and the wider property market.
When should agents submit a SAR?
The NCA’s best practice guidance states that organisations and individuals in the regulated sector have a legal obligation to submit SARs when they know or suspect money laundering or terrorist financing, and that failing to submit one when legally required could lead to prosecution, regulatory action, or both.
In practice, agents should not ignore concerns because a transaction is commercially valuable, fast-moving, or close to exchange or completion. They should consider whether the facts create a genuine suspicion and immediately follow their internal reporting process. .
Examples that may prompt further scrutiny include:
- A client cannot clearly explain the source of funds.
- Funds are coming from an unexpected third party.
- A buyer, seller, landlord or tenant is reluctant to provide identity documents.
- The ownership structure is unnecessarily complex.
- The transaction does not make commercial sense.
- A client wants to pay a large amount in cash.
- The explanation for the transaction changes or conflicts with other information.
These factors do not automatically mean a SAR is required, but they should trigger further checks and escalation where appropriate.
Defence Against Money Laundering (DAML) SARs
The MLRO must normally suspend the transaction if they suspect money laundering or terrorist financing. However, agents must avoid tipping off, which means they must not alert the client or associated parties in a way that could prejudice an investigation.
If it is not practical or safe to suspend the transaction, the agency must consider whether a Defence Against Money Laundering (DAML) (still a SAR, but a different type) is needed – permission from the NCA to continue with a specific act, such as progressing a sale, releasing funds, or completing a transaction.
Submitting a DAML request does not mean the NCA confirms the transaction is legitimate. It means the reporter is asking for a legal defence so they can proceed with the specified activity without committing a money laundering offence.
The agent should not proceed with the suspicious activity until the DAML position is clear, unless legal guidance says otherwise.
Visit the UKFI Guidance Library for detailed information about DAMLs →
How to submit a SAR
SARs (including DAMLs) should be submitted online through the NCA’s SAR Portal.
The NCA advises reporters to complete all relevant sections of the SAR Portal, include information they hold even where fields are optional, and focus the reason for suspicion on the information most relevant to the suspected money laundering or terrorist financing.
A good SAR should explain:
- Who is involved.
- What property or transaction is involved.
- What has happened or is expected to happen.
- Why the activity is suspicious.
- What criminal or terrorist property is suspected, including the value and location where known.
- What action the agency has taken so far.
Once a SAR is submitted, the reporter will no longer be able to view, save or print a copy of the submission, and the UKFIU cannot provide a copy. Agencies should make sure they retain appropriate internal records in line with their legal obligations and data protection requirements.
