Anti-Money Laundering & Identity Checks

Client information · Updated 1 October 2026

HMRC application and the checks we carry out

Fenixos submitted and paid for its HMRC anti-money-laundering supervision application on 23 September 2026. A decision has not yet been confirmed.

From 30 June 2026, HMRC supervision applies to letting agency work for a tenancy or lease of at least one month where the rent is £10,000 or more per month, including where that threshold is likely to be reached during the term. Relevant checks and risk-based procedures apply to in-scope instructions.

A letting below that threshold is not brought within HMRC money-laundering supervision solely because it is a letting. Identity, authority, fraud-prevention, financial-sanctions and Right to Rent checks can still apply.

Estate-agency work involving the acquisition or disposal of land, including in-scope property-sourcing activity, is supervised regardless of transaction value. The required HMRC application and relevant procedures must cover the activities undertaken.

Why checks are needed

Property transactions can be used to conceal criminal funds. The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, require relevant businesses to assess risk and carry out appropriate checks.

The checks that apply depend on the service, the parties and the circumstances. Estate agency and in-scope letting activity carry specific duties. UK financial sanctions requirements are separate and may apply even where a letting is outside the money-laundering supervision threshold.

Identity & address

Before proceeding with a service requiring verification, we will explain what evidence is needed and how to provide it securely. This may include a current passport, photographic driving licence or another suitable identity document, together with reliable evidence of your address.

If you cannot provide the usual documents, tell us. Suitable alternatives will be considered according to the legal requirements and the circumstances. A remote meeting does not remove the need for verification; additional independent evidence may be needed.

Please do not send identity documents through a general website enquiry. We will provide the appropriate collection instructions and privacy information first.

Companies, trusts & ownership

For a company, trust or other legal arrangement, verification can include its registration and legal status, its ownership and control, the authority of the person instructing us and the individuals who ultimately own or control it.

A company’s beneficial owners are not identified solely by its named directors. Shareholdings, voting rights and other forms of control must be considered, following the ownership chain where necessary.

Funds & transaction risk

We may need information about the purpose of the transaction, the source of funds and, where appropriate, the source of wealth. The level of evidence must be proportionate to the assessed risk and applicable law.

Relevant checks may include sanctions screening and identifying politically exposed persons. A politically exposed status is not, by itself, an allegation of wrongdoing; it informs the checks and approvals required.

Information may need to be refreshed as a transaction progresses. If required checks cannot be completed, we may have to pause or decline the service.

Reporting & confidentiality

Where the law requires a report or disclosure to an authority, that duty takes priority over ordinary client confidentiality. Legal restrictions may prevent a business from explaining whether a report has been made or why a particular step has been taken.

This client-facing summary does not replace FENIXOS’s internal risk assessment, staff responsibilities, training or reporting procedures.

Records & privacy

Where the money-laundering rules apply, the normal record-retention period is five years after the business relationship ends or the relevant transaction completes. Any longer retention must have a separate lawful justification.

Before collecting verification information, we will explain the secure method to use. Our privacy notice explains the purposes, lawful bases, providers, sharing, retention and your rights.

Speak to us

For questions about the checks relevant to your circumstances, contact Sofien Scappini at sofien@fenixos.co.uk. See HMRC’s current guidance for letting agency businesses and estate agency businesses.