The potential impact of financial sanctions regulations on relocation services.

From 14 May 2025, “letting agents” became subject to reporting obligations under the financial sanctions regulations.  Previously the regulations applied only to businesses such as financial institutions, law firms and estate agents.  The change for the relocation industry arises from the fact that the definition of “letting agents” in the new legislation could be interpreted as including businesses which deliver homesearch services:

“letting agency work means work … consisting of things done in response to instructions received from … a person (a “prospective tenant”) seeking to find land to rent for a term of a month or more”.

On a strict interpretation of this wording, homesearch agents may now be required to:

• Check their own clients (the potential tenant) and the landlord against the UK sanctions list;
• Report any matches or suspicions to the OFSI (Office of Financial Sanctions Implementation, part of HM Treasury);
• Keep records of checks and any actions taken.

Note that these sanctions rules apply to all “letting agents” — not just those already required to register under AML (Anti-Money Laundering).  Relocation businesses which never provide rental homesearch services with monthly rents over €10,000 (nor provide buyers homesearch services) still do not need to register with HMRC for AML compliance – but they may need to comply with the new sanctions regulations.

Sanctions checks can be carried out online using the OFSI Consolidated List Search (https://sanctionssearchapp.ofsi.hmtreasury.gov.uk).

ARP is seeking further clarity from the relevant regulatory authorities and will update members as soon as we have further information to share.