* New analysis finds meeting AML obligations could require at least one full-time compliance professional -- while using negotiators could cost agencies far more in lost sales

London - An average estate agency branch could need at least one full-time compliance officer, costing around £45,000 a year, to meet its anti-money laundering obligations following the introduction of new AML regulations and HMRC guidance this summer, according to analysis by Coadjute, the property market's leading AML managed service provider.

Coadjute also found that absorbing this workload within existing sales teams could prove considerably more expensive. Using negotiators to undertake the necessary compliance activity could reduce the time available for winning instructions and progressing sales, representing approximately £185,000 a year in lost sales for an average agency branch.

The findings follow changes to the Money Laundering Regulations which came into force on 30 June 2026 and HMRC's updated Anti-money laundering guidance for supervised businesses, published in July.

The guidance makes clear that businesses must take a risk-based approach to protecting themselves from money laundering, terrorist financing and proliferation financing. Estate agents must maintain a written risk assessment specific to their business and put in place appropriate policies, controls and procedures (PCPs) to manage and mitigate the risks identified.

Compliance is now a significant operational function

Coadjute analysed the practical activities required for an estate agency to meet its AML responsibilities on an ongoing basis.

These include maintaining and reviewing business-wide risk assessments and PCPs; conducting customer and transaction risk assessments; carrying out customer due diligence; assessing source of funds where appropriate; collecting missing customer information; documenting decisions and maintaining records; training staff; ongoing monitoring; identifying and escalating suspicious activity; supplier oversight; and keeping processes up to date as regulation changes.

Taken together, Coadjute's analysis indicates these activities could require at least one full-time compliance professional for an average estate agency branch, at an estimated annual employment cost of approximately £45,000.

The consequences of getting compliance wrong are also significant. HMRC's new guidance makes clear that contravening a relevant requirement of the Money Laundering Regulations is now a criminal offence and may result in criminal investigation. On conviction, offences can carry an unlimited fine and/or imprisonment of up to two years.

Importantly, an agency does not fulfil its responsibilities simply by trying to identify individual money launderers. Businesses must establish appropriate risk assessments and PCPs and ensure they are effectively implemented and complied with throughout the organisation.

Separately, failing to make a required disclosure where money laundering is suspected is itself a criminal offence. HMRC states that individuals may be referred to the Crown Prosecution Service, with prosecution possible even where there is insufficient evidence to prove that money laundering actually took place.

£45,000 compliance cost - or a potentially greater hidden cost

Coadjute's analysis suggests agencies face a choice over where this specialist workload sits. Building sufficient internal capability could mean employing at least one dedicated compliance professional at around £45,000 a year. Alternatively, distributing the work among existing staff creates a potentially much larger hidden cost.

Negotiators generate revenue by winning instructions, building relationships, conducting viewings, negotiating offers and progressing transactions. Coadjute estimates that diverting sufficient negotiator capacity to undertake the necessary AML workload could displace sales activity worth approximately £185,000 per year for an average agency branch.

Dan Salmons, CEO of Coadjute, said:

"We're seeing the end of AML as a side of desk activity. With the July HMRC guidance and the new criminal risks, AML compliance has moved well beyond being a series of checks that can simply be absorbed into someone's day job.

"Agencies really have to understand their risks, have the right policies and procedures in place, and demonstrate that those procedures are actually being followed. The big question for them is who is going to own and operate the compliance function day to day, and how is this increasingly specialist work going to get done?

"It's really not something a bit of software can solve. For other highly regulated activities like accounting, they call on professionals. It's time to start treating AML the same way".

A new compliance challenge for estate agents

The requirements present a particular challenge for independent and mid-sized estate agencies, where AML responsibility has traditionally been shared between owners, managers and negotiators alongside their principal roles.

Coadjute believes agencies increasingly need to consider not simply which AML technology they use, but who is actually responsible for operating their AML function.

Technology can accelerate individual checks, but it does not remove the requirement to assess risk, investigate exceptions, obtain missing information, document decisions, maintain policies and risk assessments, train staff and ensure procedures are followed.

The challenge for agency leaders is therefore not simply how to comply, but how to resource an increasingly demanding AML function without diverting the people responsible for winning instructions, serving customers and progressing transactions.

Ends

Notes to editors:

About the analysis

Coadjute's analysis models the resource required by an average estate agency branch to undertake recurring AML compliance activities, including customer and transaction risk assessment, customer due diligence and source-of-funds work, maintaining business-wide risk assessments and PCPs, staff training, record keeping, ongoing monitoring, suspicious activity processes, compliance oversight, regulatory updates and supplier oversight.

Coadjute analysis based on average branch with 2 negotiators doing 8 property sales per month and fully compliant activity, and show requirement for at least one full-time individual with appropriate risk and compliance skills at an annual employment cost of approximately £45,000.

Coadjute also modelled the opportunity cost of undertaking the workload using estate agency negotiators, estimating an average potential impact of approximately £185,000 per annum in sales.

Figures are Coadjute estimates and will vary according to agency size, transaction volumes, customer risk profile, operating model and existing compliance resources.

Regulatory background

HMRC published its updated Anti-money laundering guidance for supervised businesses in July 2026, following changes to the Money Laundering Regulations made by the Money Laundering and Terrorist Financing (Amendment) Regulations 2026, which came into force on 30 June 2026.

About Coadjute

Coadjute is the property market's leading AML managed service provider, helping property professionals meet their AML obligations through specialist compliance expertise, technology and connected data.

Coadjute's managed AML service takes the operational workload off estate agents, allowing branch teams and negotiators to remain focused on their buyers and sellers, winning listings and ensuring successful sales.

For further information, please contact:

Jo Burman (Marketing Director)

Email: jo@coadjute.com