Consultation on 4th Money Laundering Directive

The Government has released a new consultation on the Fourth Money Laundering Directive.

The UK is obliged to ensure adherence to EU directives until exit negotiations are concluded but, even then, Anti Money Laundering will remain a high priority and any regulations are likely to remain in situ.

The proposals are of specific interest to estate agents and letting agents (page 31 of the document which can be found below).

Proposals include possibly making the membership bodies supervise their members for anti-money laundering purposes, with HMRC continuing to supervise agents that do not belong to a recognised body.

For the first time, letting agents will also have anti-money laundering responsibilities. The consultation is seeking views on whether letting agents should carry out checks on both landlords and tenants, and if so at what stage.

The consultation also addresses the very thorny issue of sub-agents, saying that where there is a sub-agent acting on behalf of a principal estate agent, a sub-agent cannot rely on the due diligence performed by the main agent.

However, the consultation introduces the thought that subject to certain provisos, the sub-agent might be able to rely on it.

Download the consultation document here:

Michael Day, Managing Director of Integra is a recognised industry expert on compliance and is holding an updated course on Money Laundering Regulation and Consumer Protection Regulation compliance on November 2nd in London.

Training staff is one of the mandatory requirements on agents under the Regulations.

Details of the course and booking arrangements can be found here: