A new survey suggests property-sector compliance budgets are heading higher, even as firms struggle with systems that do not work together. For estate agents and home movers, the question is whether the additional spending will prevent more financial crime — or simply make buying and selling a property more cumbersome.
Anyone who has bought a home recently may recognise the experience. The estate agent asks for proof of identity, the conveyancer requests much the same information a few days later, and the mortgage lender conducts its own checks. Then come the questions about where the deposit originated, why money has moved between accounts, or whether a relative contributing to the purchase can provide evidence of their funds. Each request may have a legitimate purpose, but to the person supplying the documents it can feel as though nobody involved in the transaction speaks to anybody else.
Estate agents see another side of the same problem. Staff have to verify customers, assess potential financial crime risks, maintain records and satisfy the requirements of the business’s anti-money laundering procedures. Much of that work takes place before the agency receives its commission, and some of it must be completed even where a transaction subsequently falls through. In a market where agreed sales are under pressure, the cost of carrying out those checks becomes an increasingly important part of running the business.
Research commissioned by identity-verification company Thirdfort suggests those costs and workloads are weighing on compliance professionals. According to a survey reported by Property Industry Eye on 16 October 2026, 61% of 200 senior compliance professionals expected their firm’s anti-money laundering budget to increase over the following year, while 51% anticipated expanding their teams. Some 85% said compliance demands had increased during the previous 12 months.
Those figures are expectations and self-reported experiences rather than evidence of how much businesses have actually spent. The publicly available reporting does not establish precisely how many respondents worked in estate agency rather than other property-related businesses, or disclose the full survey methodology. Thirdfort also supplies AML technology, so it has a commercial interest in the problems the research identifies. Its findings are worth examining, but they cannot establish that estate agencies throughout the country are experiencing the same pressures.
The most interesting result concerns the way compliance work is organised. Some 81% of respondents reportedly identified fragmented systems as an ongoing challenge, while larger businesses were less confident in their procedures than smaller firms. That suggests the question facing estate agencies is not simply how much more they need to spend, but whether the money already being spent is producing the right results.
Why buyers are checked repeatedly
Property is an attractive way to conceal criminal wealth because transactions involve substantial sums of money, assets that may hold value over many years and, sometimes, complicated arrangements for ownership and funding. An estate agent may not handle the purchase money directly, but the business can encounter suspicious circumstances before other professionals become involved.
HMRC’s estate agency anti-money laundering guidance, updated on 13 October 2026, makes clear that both buyers and sellers are customers for due-diligence purposes. The agent must establish the seller’s identity before entering the business relationship to market the property. A buyer must also be checked before the relevant business relationship is established, with HMRC recommending that the process begins early enough to prevent avoidable costs and delays.
That distinction is important in everyday sales. An agent may begin preparing a property for marketing before a purchaser exists, but cannot leave the buyer’s identity verification until the transaction is effectively beyond recovery if something suspicious emerges. HMRC’s guidance recommends beginning buyer due diligence as soon as practicable after initial contact and completing it before the relevant legal deadline. Waiting until solicitors are preparing to exchange contracts may be technically different from carrying out checks when terms are first agreed, but it can create unnecessary commercial risk.
The depth of investigation also depends on the circumstances. A straightforward sale involving individuals whose identity and funding arrangements are readily established may not require the same scrutiny as a transaction involving complex corporate ownership, a politically exposed person or connections to a high-risk jurisdiction. Where enhanced due diligence is required, the agent may need to examine not only the immediate source of the purchase money but also the wealth from which it originated.
HMRC’s estate agency sector risk assessment identifies the potential use of property transactions to conceal beneficial ownership and move illicit funds. The 2025 National Risk Assessment classified estate agency services as presenting a medium money-laundering risk, while identifying significant risks in the wider property sector. The distinction is important: most ordinary transactions are not suspicious, but property remains sufficiently attractive to criminals that effective checks cannot be regarded as an optional administrative exercise.
For home movers, the repeated requests arise partly because the organisations involved are examining different aspects of the transaction. The estate agent needs to understand its customers and identify suspicious circumstances. The conveyancer has separate responsibilities connected with the legal transfer and movement of funds. A lender must assess the borrower and the proposed mortgage while complying with its own financial crime obligations. The overlap is real, but so are the differences.
There is more scope to reduce that overlap than the familiar complaint that every professional must start from nothing might suggest. Under HMRC’s guidance on third-party reliance, an estate agency may rely on customer due diligence undertaken by another qualifying regulated business, provided the necessary arrangements exist and the information required by law can be obtained. The relying agency remains responsible for failures, and reliance does not remove obligations to address other relevant risks.
Crucially, using an electronic identity-verification provider is not the same as formally relying on another regulated business. A technology supplier may help an agency verify documents, identify potential sanctions matches or screen customers against relevant databases. But using that service does not mean the supplier has taken over the agency’s legal responsibilities. Nor can an agent simply assume that a conveyancer’s checks are sufficient because the solicitor has already seen the customer’s passport. Formal reliance has specific legal conditions; ordinary use of verification software or an informal assurance from another professional does not satisfy them.
That difference explains why eliminating repeated requests is more complicated than creating a single shared identity record. Information can be collected efficiently, but somebody still has to determine whether it is sufficient, current and appropriate for the risks involved. A faster verification process is valuable only if it preserves the judgement and accountability that effective due diligence requires.
The cost is not just another software subscription
The economics of compliance are particularly awkward for estate agencies because much of their work is undertaken before any sale completes. Under a conventional commission-based arrangement, the agent may spend money marketing a property, handling enquiries and conducting required checks without receiving the expected commission if the transaction collapses. That is not true of every agency fee model, but it is an important characteristic of much of the sector.
The point at which a cost arises therefore matters as much as its amount. Verifying a seller at instruction is an expense incurred before the agency knows whether it will find a buyer. Due diligence on a prospective purchaser may involve further staff time and technology charges even if that purchaser subsequently withdraws. A completed sale must help sustain the cost of work performed on instructions and transactions that never generate completion-based commission.
This makes the effectiveness of an agency’s processes a commercial issue, not merely a matter for its compliance officer. A firm that repeatedly collects the same information, manually transfers it between systems or spends hours resolving avoidable discrepancies is using resources that could otherwise support customers and progress sales. Conversely, cutting verification work simply to protect margins could expose the business to regulatory sanctions, reputational damage and financial crime.
Different agency models face different pressures. A single-office independent agency may have a relatively simple workflow but little spare capacity when a complex case needs specialist attention. A larger corporate group may employ dedicated compliance staff yet struggle to coordinate customer records between branches, acquired businesses and separate technology platforms. Franchise networks and businesses using self-employed agents may face additional questions about which organisation controls the process and bears responsibility for compliance.
That makes another Thirdfort survey finding interesting, although far from conclusive. According to the published results, 59% of respondents from firms employing 25 people or fewer considered their compliance processes very or extremely effective, compared with 46% at firms with more than 150 employees. The figures reflect respondents’ opinions, not independently measured compliance performance, and the underlying group sizes have not been disclosed. Still, they challenge the assumption that the businesses with the most staff and largest budgets necessarily have the best systems.
A smaller agency using one consistent process may find it easier to understand exactly which checks have been completed and which concerns still require investigation. A larger organisation may have more expertise available but also more opportunities for information to become separated between departments. Size can provide resources, but it does not remove the need for effective coordination.
Technology can improve that coordination when it reduces repetitive data entry, keeps an accessible audit trail and allows staff to see what evidence has already been obtained. Automated verification may help identify routine discrepancies and free experienced employees to concentrate on unusual transactions. But additional software can just as easily become another subscription, another login and another source of alerts if it does not fit the firm’s existing systems.
The value of the investment depends on what problem it solves. More compliance staff may be justified where a business has too few trained people to investigate complex transactions properly. Better software may be justified where manual processes create errors or make important information difficult to retrieve. Neither is a worthwhile solution simply because a larger budget creates the appearance of greater diligence.
There is a further difficulty in measuring effectiveness. Counting the number of identity checks completed is straightforward, but it says little about whether an agency recognised suspicious financial arrangements or made sound decisions when unusual circumstances arose. A high volume of automated alerts may demonstrate that a system is active without showing whether staff can distinguish genuine risks from routine false positives.
For an agency principal, the useful questions concern whether important risks are being identified, whether decisions can be explained and evidenced, and whether avoidable administrative work has been reduced. Compliance has to withstand regulatory scrutiny, but it also needs to operate effectively in a business whose income depends on progressing property transactions.
What better AML compliance should achieve
The consequences of inefficient checks are visible to buyers and sellers, even when they have little understanding of the legislation behind them. A purchaser may provide proof of identity to the estate agent and then be asked for similar documents elsewhere. A gifted deposit may trigger additional questions, while changes to funding arrangements can lead to further enquiries after an offer has been accepted. Some of these checks will be necessary, but poor communication can make them more disruptive than they need to be.
Estate agents can reduce that frustration by establishing what information is likely to be required, explaining why it is needed and identifying potential difficulties before a transaction reaches a critical stage. Buyers can then gather suitable evidence earlier, while sellers have greater confidence that unresolved compliance questions are less likely to emerge unexpectedly.
That does not mean an agent can promise that a lender or conveyancer will accept the same documents without further questions. Nor should customer convenience override duties to investigate suspicious activity or protect confidential information. Better coordination must work within those obligations, rather than assume that sharing documents automatically satisfies every professional involved.
The distinction matters because a delayed transaction is not necessarily evidence of poor compliance management. Some delays arise precisely because a professional has identified circumstances that deserve investigation. The relevant question is whether the delay was necessary to assess a genuine risk or resulted from disorganisation, unclear responsibilities or repeated requests that could reasonably have been anticipated.
The pressure to improve efficiency also needs to be considered alongside the underlying purpose of the rules. Money laundering through property is not a theoretical concern invented by compliance suppliers. Criminals may use companies, trusts, intermediaries and complicated funding arrangements to disguise beneficial ownership or the origin of money. An estate agency that recognises an unusual transaction early can contribute valuable information even though the eventual transfer of funds is handled elsewhere.
Effective AML controls therefore protect more than the individual business. They help prevent property from being used to legitimise criminal wealth and support confidence in the integrity of the housing market. Firms that take those responsibilities seriously should not be disadvantaged commercially by competitors that treat checks as an expense to be avoided.
That is why the solution cannot simply be fewer checks, any more than it can automatically be more staff or another technology platform. The aim should be better identification of risk, clearer accountability and less unnecessary work surrounding the checks that genuinely matter.
Thirdfort’s survey provides a timely indication of the pressures compliance professionals say they face, but it cannot establish whether higher spending is producing better outcomes. That would require more than predictions about budgets and subjective confidence in existing procedures. Independent supervisory findings, evidence of recurring weaknesses and reliable measures of processing efficiency would give a clearer picture of where firms are improving and where additional resources are being absorbed without sufficient benefit.
Estate agents have good reason to question how compliance expenditure is organised, especially when so much of their income depends on transactions reaching completion. Home movers have equally good reason to question why familiar documents are requested repeatedly and why responsibilities are not always explained clearly.
Neither concern diminishes the importance of preventing financial crime. The industry’s challenge is to make necessary checks rigorous without making them needlessly cumbersome, and to distinguish expenditure that genuinely improves risk management from expenditure that merely adds another layer of administration.
For estate agencies, that is the commercial test behind the latest survey. For buyers and sellers, it is whether better organised compliance can provide proper protection without turning an already complicated property transaction into an unnecessarily difficult one.
This article provides general news and analysis of anti-money laundering compliance in UK estate agency as at 17 October 2026. It is not legal or regulatory advice. Businesses should consult the current legislation and HMRC guidance and obtain specialist advice where necessary. The Thirdfort survey figures are attributed to publicly reported research whose full methodology and sector breakdown have not been independently verified.
