New Anti-Money Laundering regulations (AML) came into force on May 14, 2025, whereby agents must check that all their clients meet the new AML regulations.

It is unclear whether landlords have to meet this as well, so we wrote to the body that oversees this, and got the following response:

Thank you for your enquiry regarding sanctions checks for self-managed landlords.

This is a complex area of legislation, and it is currently under review by both HMRC and OFSI. We are awaiting definitive guidance from both organisations, and as soon as further clarity is provided, we will update you accordingly.

In the meantime, I am sorry that we cannot provide a more conclusive response at this stage.

We will keep you informed.

This is the question we asked:

We are writing on behalf of our landlord association to seek urgent clarification regarding the new Anti-Money Laundering regulations that came into force on May 14, 2025.

Our members, who include both self-managing landlords and those using letting agents, are confused about their new legal obligations. While it is understood that letting agents must conduct checks on new clients, the requirements for existing clients and self-managing landlords are less clear.

We would be grateful if you could provide a definitive “yes” or “no” answer for each of the following scenarios to which of these must carry appropriate sanction checks, as it is critical for us to correctly advise our members:

• A letting agent taking on a new landlord or a new tenant.
• A letting agent with existing landlords and tenants.
• A landlord who manages their own properties and does not use an agent:
  • For a new tenant
  • For an existing tenant

One of our members has presented a strong argument that self-managing landlords are now considered “sole practitioners” and must comply.

• Government advice states that a firm or sole practitioner that carries out, or whose employees carry out, letting agency work. [from 14 May 2025]
• And that a Sole Practitioner: A sole practitioner is an individual who practices a profession or trade independently, without being part of a larger organization or company. In the context of property, this means the landlord owns and manages the property themselves, handling all related tasks like finding tenants, collecting rent, and handling maintenance.