Financial sanctions
for letting agents

The Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855 as amended) extended financial sanctions obligations to letting agents from 14 May 2025. The Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) provides the primary legislative framework. OFSI guidance EA(S)02 sets out the specific compliance expectations for letting agents.

• Russia (Sanctions) (EU Exit) Regulations 2019 — SI 2019/855 as amended
• Sanctions and Anti-Money Laundering Act 2018 — primary framework
• OFSI guidance EA(S)02 — compliance expectations for letting agents
• Letting agents classified as relevant firms from 14 May 2025
• Obligation applies regardless of whether the tenancy involves a Russian national

You must screen all three parties in a letting transaction against the full OFSI consolidated list. Screening a partial subset is not compliant. You must screen against the current version of the list at the time of each check.

• Landlords: screen at the point of instruction
• Tenants: screen at the point of offer acceptance
• Guarantors: screen before countersigning the tenancy agreement
• Must check against the full OFSI consolidated list — not a partial subset
• Re-screen if there is reason to believe circumstances have changed

If a screening returns a match or you have reasonable suspicion that a party is subject to financial sanctions, you must report to OFSI as soon as practicable using the GOV.UK reporting portal. Failure to report is a separate criminal offence. Tipping off the subject of an investigation is also a criminal offence.

• Report to OFSI as soon as practicable on reasonable suspicion
• Use the GOV.UK reporting portal — ofsi.blog.gov.uk
• Failure to report is a separate criminal offence from the underlying breach
• Tipping off the suspected party is a criminal offence
• Do not proceed with the transaction until OFSI has been notified

Penalties under SAMLA 2018 and the Russia Sanctions Regulations apply to individuals as well as corporate entities. Directors and senior managers are personally liable.

• Deliberate breach: up to seven years' imprisonment and/or an unlimited fine on conviction
• OFSI civil monetary penalties: over £1 million in serious cases
• Penalties apply to individuals including directors and senior managers
• Corporate entity and individual may both be penalised for the same breach
• Penalties apply for failure to report as well as for the underlying breach

Financial sanctions screening and AML Customer Due Diligence are separate legal obligations. Meeting one does not satisfy the other. You must comply with both the Money Laundering Regulations 2017 and the financial sanctions regime independently.

• AML CDD under MLR 2017 — required for all estate agents supervised by HMRC
• OFSI sanctions screening under SI 2019/855 — required for all letting agents from May 2025
• Both checks must be completed and documented separately
• A clear AML result does not mean a party is clear of financial sanctions
• Both sets of records must be retained for five years

EstateHQ includes OFSI screening within the dashboard. The following features are live in the current platform.

• OFSI screening module — screen landlords, tenants, and guarantors
• Mandatory reporting banner with GOV.UK link on confirmed match
• Timestamped audit trail of every screening with result recorded
• Linked to the relevant applicant and instruction records
• Integrated with AML risk assessment workflow