Under Regulation 18 of the Money Laundering Regulations, every estate and letting agency must have a written risk assessment of the money-laundering and terrorist-financing risks it faces. It's not a tick-box — it's the foundation HMRC expects your policies and procedures to be built on. A missing or generic one is a common, avoidable reason agents get penalised.
What your risk assessment must cover
HMRC expects you to consider, and document, risk across these areas:
- Customer risk — cash buyers, overseas buyers, companies and trusts, politically exposed persons, parties you never meet face to face.
- Geographic risk — buyers, sellers or funds connected to higher-risk jurisdictions.
- Product/service & transaction risk — high-value sales, unusual funding routes, rapid back-to-back transactions.
- Delivery-channel risk — remote onboarding, third-party introducers, reliance on others' checks.
For each, you state the risk, how likely/serious it is for your business, and the controls you apply to reduce it. That's what turns a generic template into your assessment.
The structure of a compliant assessment
- Business overview — what you do, where, and the kinds of clients and transactions you handle.
- Risk areas — the four categories above, scored for your business.
- Controls & mitigation — the CDD, screening and reporting steps that bring each risk down.
- Conclusion & residual risk — your overall risk rating and anything that needs extra attention.
- Sign-off & review date — dated, owned by your nominated officer, reviewed regularly and after any big change.
Get the template — and the rest of the set
Our editable AML pack for estate & letting agents includes a Reg 18 risk-assessment template structured exactly like this, alongside the policies, controls, nominated-officer and CDD documents HMRC checks first — written to the regulations and ready to make your own. Not sure where your gaps are yet? Start with the free 2-minute self-check, or read the complete AML guide.
A missing Reg 18 risk assessment is one of the first things HMRC checks — and agents have been fined over £835,000, mostly for missing paperwork. A consultant charges £1,000–£3,000 for the same documents.
✓ Instant download · fully editable · yours to keep, no subscription · ✓ Mapped to the Money Laundering Regulations · ✓ Built inside a CQC-rated Good, ISO-certified business · ✓ 14-day make-it-right guarantee (file faulty or not as described, we fix it or refund)
🎁 Founding offer — 10% off any pack with code LAUNCH10 · ends 30 June.
Complete your compliance: every agency is also an employer — add the Employment Rights Act HR pack, or get HR + Health & Safety together in the Small-Business Essentials bundle and save.