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AML documents — UK supervised sectors

Supervised for money laundering?
Your risk assessment and procedures, written for your firm.

Two documents, both required in writing. A practice-wide risk assessment under regulation 18, and policies, controls and procedures under regulation 19.

Every supervised business has to hold both, and be able to hand them over on request. We build them for four sectors — HMRC-supervised estate and letting agents, accountancy service providers and trust or company service providers, and SRA-regulated solicitors' firms in England and Wales — and each sector gets its own questions, its own risk factors and its own regulator cited, not an estate agent's pack with the words swapped. Most firms we speak to have neither document, or have a template bought years ago that was never written against their own business, which is the one thing regulation 19 asks it to be. We show the working behind every risk rating so you can check it, correct it and defend it.

Led by a Chartered Accountant — a CA ANZ member with 20+ years of experience across public practice, business operations, audit, and government sectors.

Start now — 20 minutes →See a full sample packAsk a question first
Generated from your answers. Not a template with your name on it.
21 days
To supply what HMRC asks for, once it asks — reg 57(3)
160
Penalties against estate agency businesses, Apr–Sep 2025
£295
Launch pricing, documents pack
Who this is for

Four sectors, and the question that decides each one.

Who supervises you decides which regulator your documents cite, which guidance they are written against and which forms they name — so it is the first question on the form, not the last. Answer it wrong and every page of your pack names the wrong body. We ask before you pay, and where the answer means we are the wrong people, we say so and stop.

Estate and letting agents
Supervised by HMRC
Estate agency work is caught by regulation 13(1)–(2) whatever it is worth. Lettings work is different: a letting agent is caught by regulation 13(4) only where a tenancy is concluded for a term of a month or more at a monthly rent of £10,000 or more — £120,000 a year, which most high-street agents never see. If you do sales as well, that threshold does not help you.
Accountancy service providers
Supervised by HMRC — not by a professional body
Regulation 7(1)(c)(iv) gives HMRC the auditors, external accountants, bookkeepers and tax advisers that no Schedule 1 professional body supervises. So if you or your principals are members of ICAEW, ACCA, ICAS, CAI, AAT, AIA, ATT, CIMA, CIOT, IAB, IFA or ICB, that body supervises you and this is the wrong pack — we will tell you rather than sell it. Unaffiliated bookkeepers, payroll bureaux and tax agents are exactly who it is for.
Trust or company service providers
Supervised by HMRC — and you must not trade until registered
Company formation, registered office and correspondence addresses, acting or arranging for someone to act as a director, company secretary, partner, trustee or nominee shareholder. The rule here is stricter than an estate agent's: regulation 56(1)(c) says you must not carry on the business at all until HMRC has registered you, and the only concession is confined to applications made before 10 January 2020. There is no trading while you wait. Most trust or company service providers are supervised by a legal or accountancy professional body rather than HMRC; if yours is, this is the wrong pack.
Solicitors' firms
Regulated by the SRA, in England and Wales
The gate here runs the other way. There is no HMRC registration in your sector at all — the Law Society is your supervisor under regulation 7(1)(b) and Schedule 1, and it delegates to the SRA. So the pack cites the SRA's sectoral risk assessment, its warning notices, LSAG and the mySRA forms FA10 and FA10b, and nothing in it asks about HMRC. If you are regulated by the Council for Licensed Conveyancers, the Bar Standards Board or CILEx Regulation, or you practise in Scotland or Northern Ireland, those are different regulators with their own risk assessments and their own forms.
Not yet: High value dealers and Art market participants.

Both are supervised by HMRC and both need the same two documents, and we have not built them. The risk factors, the thresholds and the guidance are genuinely different, and handing you another sector's pack with the words swapped would be worse than saying no. Ask anyway and you will get a straight answer, with no payment link, because there is nothing for you to pay for yet.

Why now rather than later

Twenty-one days is enough to send documents. It isn't enough to write them.

When you apply to register with HMRC, regulation 57(2)(f) lets HMRC specify, as information it requires, a risk assessment which satisfies the requirements in regulation 18. If it issues a requirement for further information, regulation 57(3) gives you 21 days beginning with the date that requirement is issued to provide it. Under regulation 59(1)(a), HMRC may refuse to register you where a requirement imposed under regulation 57 has not been complied with.

Read that carefully, because the version that circulates is wrong in a way that matters: the 21 days runs from HMRC's letter, not from the day you applied, and refusal is discretionary rather than automatic. So there is no countdown on your calendar. The letter simply arrives, and from that moment you have three weeks — which is plenty of time to attach two documents to an email, and nowhere near enough to write them properly for the first time.

HMRC's own registration guidance tells applicants to complete a risk assessment and put policies, controls and procedures in place before applying, and says in terms: "We may reject or refuse your application if you do not have these in place."

The honest version of the enforcement story

Nearly half of every penalty HMRC published landed on an estate agent, and almost all of it was late registration.

In the list HMRC published covering 1 April to 30 September 2025, there were 334 penalties across every sector it supervises. 160 of them were against estate agency businesses, totalling £826,655. That is the population HMRC is actively working through.

Now the part most people selling AML packs leave out, because it is inconvenient: 149 of those 160 were for failing to apply for registration at the required time — regulation 56 — rather than for a document failure. So we are not going to tell you agents are being fined for not having a risk assessment. On the published evidence, they are being fined for not registering properly.

Which leads to the same place by a more honest route. Registration is where this goes wrong, registration is where HMRC can ask for your risk assessment, and regulation 59(1)(a) is what happens if you cannot produce it. Get registered, on time, with the documents already sitting there.

The pattern holds across the other HMRC sectors on the same list. 113 penalties were against accountancy service providers, totalling £495,220, and 106 of those were regulation 56 again. Ten were against trust or company service providers, totalling £80,206, nine of them regulation 56 — which bites harder in that sector, because regulation 56(1)(c) does not let you trade while your application is pending at all. Solicitors' firms are not on this list: the SRA publishes its own enforcement, and its named failures are the opposite shape — client and matter risk assessments, source of funds, and firm-wide risk assessments missing or written from a template.

Why a template can't do this

The regulation asks for something a download cannot be.

Regulation 19(1)(a) requires policies, controls and procedures that mitigate the risks of money laundering and terrorist financing identified in any risk assessment undertaken by the relevant person under regulation 18(1).

That is not a drafting preference, it is the test. A template was not written against any risk assessment, let alone yours — so it cannot meet regulation 19(1)(a) however good the writing is. It is the wrong shape, not the wrong quality.

So each section of your policies opens by naming the risk it answers and the rating that risk carries in your own assessment. Change an answer, and the rating moves, and the policy that answers it moves with it.

Delivery channelsExample
Only 20% of customers met in person+4
Business arrives via introducers+2
Some introducers based overseas+2
Part of ID checking outsourced+1
Inherent ratingMedium-High
Illustrative. Each finding in your own assessment names the answer it came from, so you can check it and change it.
What you get

Four documents, generated from your answers.

01
Your practice-wide risk assessment
Regulation 18. The five risk factors the regulation names — customers, countries, products and services, transactions, delivery channels — each rated from your own answers, with the findings that produced the rating printed underneath it. Plus the separate proliferation financing assessment regulation 18A requires, which is the thing template packs almost always miss.
02
Your policies, controls and procedures
Regulation 19. Written against the ratings in document 01, section by section, because regulation 19(1)(a) requires the policies to mitigate the risks identified in your risk assessment. Includes the senior management approval block regulation 19(2)(b) requires, and the record of internal communication required by 19(1)(c)(iii) — the requirement most often missed.
00
A gap analysis
What is missing, what is already overdue, and what is genuinely fine — ordered so you know what to do first. It includes a check of what is on your books right now — instructions, engagements or matters, depending on your sector — against the point at which the checks actually fall due, which is the part that finds a live problem rather than a paperwork one.
03
Your compliance calendar
Your renewal date and fee, the 14 days you have to tell HMRC who your officers are, the training refresh, the review dates — and the events that force a review whenever they happen, like taking on a new service line or a new identity provider.

Anything you cannot answer comes back marked needed from you rather than guessed at, and anything genuinely unsettled comes back flagged rather than quietly decided. Send the answers and we rebuild.

What it costs

Two flat fees. Launch pricing.

Documents Pack
£295
Launch pricing
You answer the questionnaire, we build the pack, you adopt it.
→Regulation 18 risk assessment — five factors, each rated with the working shown
→Regulation 18A proliferation financing assessment, which templates leave out
→Regulation 19 policies, controls and procedures, written against your ratings
→Gap analysis and compliance calendar
Done with you
£495
Launch pricing
The same pack, plus the call that makes it right before you adopt it.
Paid in two halves: £247.50 to begin, by card on the next screen, and the balance invoiced when you approve the pack.
→Everything in the pack above
→A working call through the gap analysis, in the order it should be done
→The open items filled in properly rather than left marked
→A straight answer on anything the pack flagged rather than decided

Both prices are launch pricing, confirmed in writing before anything is charged. The Documents Pack is paid in full up front and is refundable until we start generating your documents; done-with-you takes half to begin and the balance on your approval, before anything is delivered. Separate from our fees, HMRC charges its own — £300 to apply, £400 per premises at registration and again each year, and £40 per person for the approval checks on beneficial owners, officers and managers. Those are paid by you to HMRC and we never handle them.

Before you buy anything

If you only do lettings, you may not need this at all.

A letting agent is caught by regulation 13(4) only where an agreement is concluded for a term of a month or more at a monthly rent of £10,000 or more. That is £120,000 a year on a single tenancy. Most high-street letting agents never conclude one, and on their lettings work alone they are not letting agents for these purposes.

One detail worth knowing, because it changed recently and the guidance has been slow to catch up: that threshold was 10,000 euros until 30 June 2026, when S.I. 2026/621 replaced it with £10,000. If you are anywhere near the line, it is worth checking against the sterling figure.

If you also do sales, none of that helps you — you are captured as an estate agency business regardless of your lettings book. Tell us your highest monthly rent and what else the business does, and you will get a straight answer before anything is invoiced. We would rather tell you that you do not need this than take £295 for a pack you cannot use.

The boundaries

What we don't do.

Being straight about the limits is part of the pitch, not a disclaimer bolted to the bottom of it.

Suspicious activity reports
Reporting to the National Crime Agency is your nominated officer's duty, under Part 7 of the Proceeds of Crime Act 2002. We do not make reports and could not make them for you.
Being your MLRO
Regulation 21(3) requires the nominated officer to be an individual in your firm, and regulation 21(1)(a) requires the compliance officer to come from your board or senior management. Both roles stay with you. Anyone offering to be your outsourced nominated officer is selling you something the regulation does not allow.
Submitting your registration
You apply to HMRC yourself, from your own account, and you pay the fees. We tell you what to expect at each step and make sure the documents exist before you need them.
Audit or assurance
Nothing here is verified. It is prepared from the answers you give, and every document says so at the top. We also cannot perform the independent review in regulation 21(1)(c) — we wrote the policies, so reviewing them would not be independent.
Who's actually doing the work

Expertly designed. Commercially grounded.

Led by a Chartered Accountant — a CA ANZ member with 20+ years of experience across public practice, business operations, audit, and government sectors.

Chartered Accountant Led
A CA ANZ member, qualified over twenty years, leads the work.
Government & Audit Backed
Built on experience in audit and government finance, where the file has to stand up to inspection.
Commercially Minded
Years spent running businesses, not only advising them — so the process fits around how your firm actually works.

We prepare; you adopt. Regulation 19(2)(b) requires your policies to be approved by your senior management, so the approval is yours and so is everything that follows from it. Your nominated officer under regulation 21(3) and your compliance officer under regulation 21(1)(a) are your own people — the regulation requires an individual in your firm, and we could not hold either role if we wanted to.

This is not an audit, review or other assurance engagement, and it is not legal advice. Everything is prepared from the answers you provide and has not been independently verified — every document in the pack says so on its face.

FAQ

Questions firms actually ask.

Which businesses is this actually for?
Four supervised sectors, and each has a gate we check before you pay. HMRC-supervised estate and letting agents. HMRC-supervised accountancy service providers — which means the ones no professional body supervises, because regulation 7(1)(c)(iv) gives HMRC only the auditors, accountants, bookkeepers and tax advisers a Schedule 1 body does not; if you are an ICAEW, ACCA, AAT, CIOT, ICB or IFA firm, your body supervises you and we are the wrong people. HMRC-supervised trust or company service providers, where regulation 56(1)(c) says you must not trade at all until you are registered. And SRA-regulated solicitors' firms in England and Wales, where the gate runs the other way — there is no HMRC registration in that sector, the supervisor is the Law Society through the SRA, and a firm regulated by the CLC, the Bar Standards Board or CILEx Regulation, or practising in Scotland or Northern Ireland, needs its own regulator's material rather than ours. High value dealers and art market participants we have not built, and we say so rather than adapt someone else's pack.
Do the four sectors get the same documents?
The same four documents, built from different questions against different guidance. The statutory spine is shared because it is the same regulations — regulation 18 risk assessment, regulation 18A proliferation financing, regulation 19 policies, regulation 21 officers, regulation 40 records. Everything else is the sector's own. An estate agent is asked about instructions on the books and the point at which a buyer and a seller each fall due for checks; a trust or company service provider is asked about formations, nominee holdings and address services, and is told there is no trading while an application is pending; an accountancy practice is asked about client money, engagement letters and work taken through other firms; a solicitors' firm is asked about matters, the client account and the four separate points at which LSAG says the checks must be finished. The guidance cited differs too — HMRC's AMLG manual for the HMRC sectors, LSAG and the SRA's sectoral risk assessment for solicitors.
What exactly does the law require me to have in writing?
Two things, and they are separate. Regulation 18 requires a written practice-wide risk assessment covering five named factors — your customers, the countries you operate in, your products and services, your transactions, and your delivery channels — kept up to date, and producible to HMRC on request. Regulation 19 requires written policies, controls and procedures that mitigate the risks that assessment found, proportionate to your size and approved by your senior management. Regulation 18A adds a second risk assessment for proliferation financing. Most agencies we speak to have neither, or have a template that was never written against their own business.
Why can't I just download a template for £25?
You can, and plenty do. The problem is structural rather than a matter of quality: regulation 19(1)(a) requires your policies to mitigate the risks identified in the risk assessment undertaken by you under regulation 18(1) — your assessment, not a general one. A template was not written against any risk assessment, let alone yours, so it cannot satisfy that requirement however well drafted it is. What we produce is generated from your answers, and every risk rating in it shows the answers that produced it.
What is the 21-day thing I keep hearing about?
It is regulation 57(3). When you apply to register with HMRC, regulation 57(2)(f) lets HMRC specify, as information it requires, a risk assessment which satisfies the requirements of regulation 18. If HMRC issues a requirement for further information, you have 21 days beginning with the date that requirement is issued to provide it — and under regulation 59(1)(a) HMRC may refuse your registration if a requirement imposed under regulation 57 has not been complied with. Note what that is and is not: the 21 days runs from HMRC's letter, not from the day you applied, and refusal is discretionary. It is not a countdown you can see coming, which is the whole argument for having the documents already adopted. Three weeks is enough time to send documents; it is not enough time to write them properly.
I'm a letting agent. Am I even covered?
Quite possibly not, on your lettings work alone, and we would rather tell you that than sell you a pack. A letting agent is caught by regulation 13(4) only where an agreement is concluded for a term of a month or more at a monthly rent of £10,000 or more — that is £120,000 a year, and most high-street letting agents never conclude such a tenancy. One thing worth knowing: that figure was 10,000 euros until 30 June 2026, when S.I. 2026/621 replaced it with £10,000. If you also do sales work you are captured as an estate agency business regardless of your lettings book. Tell us your highest monthly rent and what else you do, and we will give you a straight answer before anything is invoiced.
How long does it take?
The questionnaire is a web form you fill in after you pay — usually under an hour of your time — and the pack follows. It saves as you go and the link reopens it exactly as you left it, so you do not have to finish in one sitting. The longest part is you going and finding the things you do not know off the top of your head — when your last staff training was, whether anyone told HMRC who your nominated officer is. Anything you cannot answer comes back marked as needed from you rather than guessed at, so you can send it and we will rebuild.
Do the documents actually differ between agencies, or is it the same file with my name on it?
They differ, and you can see where. Each of the five risk factors is scored from your specific answers and prints the findings that produced its rating along with the field each came from. A small regional agency with a domestic customer base and a well-controlled prime-central-London firm come out looking nothing alike per factor. If you disagree with a rating, change the answer and we rebuild it — which is not a conversation you can have with a PDF you downloaded.
Will this stop me getting a penalty?
We are not going to promise you that, and you should be wary of anyone who does. Here is the honest picture from HMRC's own published enforcement list for 1 April to 30 September 2025: of 334 penalties published, 160 were against estate agency businesses — but 149 of those 160 were for failing to apply for registration at the required time, not for document failures. So the single most important thing is to be registered, properly and on time. Having your risk assessment and procedures ready is what keeps the registration process from going wrong, and what you produce when HMRC asks.
Who is actually doing this work?
A chartered accountant, working from the legislation rather than from a competitor's template. Every statutory claim in your pack traces to a source we fetched from legislation.gov.uk or gov.uk, and where something is genuinely unsettled — like exactly where lettings work stops being estate agency work, or where LSAG still prints €15,000 for a threshold regulation 27(2) now sets at £12,000 — the pack flags the question rather than quietly deciding it for you.
Get started

Tell us about your firm.

Not sure whether you're captured, who supervises you, or whether you already registered years ago and forgot? Say so. We'll come back with a straight answer on what you need — including that you need nothing from us — before anything is invoiced.

Nothing to pay now, and no obligation. If it turns out we're the wrong people — a lettings-only agency under the £10,000 monthly rent threshold, an ICAEW or ACCA firm its own body supervises, or a practice the CLC regulates rather than the SRA — we'll tell you that rather than sell you a pack you can't use.

The short version
An hour of answers, then it's done.

You answer questions about your own business — no statutory language, no jargon. We build the risk assessment, the policies, the gap analysis and the calendar, and show the working behind every rating. You read it, correct anything we got wrong, and adopt it.

“Compliance shouldn't paralyze your operations. Our frameworks are developed and led by a Chartered Accountant with 20+ years of experience bridging the gap between government audit requirements and real-world business operations.”

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Also from Deplexify

Have the documents before HMRC asks for them.

A risk assessment under regulation 18 and policies under regulation 19, built from your answers with the working shown. £295 for the pack, £495 done with you — launch pricing, confirmed before anything is invoiced.

Start now — 20 minutes →

We prepare anti-money laundering documents for your review and adoption. This is not legal advice, and it is not an audit, review or other assurance engagement. Your policies are approved by your own senior management under regulation 19(2)(b), and your nominated officer and compliance officer are your own people under regulation 21. We do not make suspicious activity reports and do not submit anything to HMRC on your behalf. Deplexify is not affiliated with, endorsed by, or acting on behalf of HM Revenue & Customs.

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