Estate agents

Real estate is consistently identified as a high-risk sector for money laundering by the FATF and national risk assessments. The sector's vulnerability stems from high-value transactions, complex ownership structures, and the use of property as a store of value.

  1. Property transactions involve large sums that can be used to integrate illicit funds into the legitimate economy
  2. Beneficial ownership is frequently obscured through shell companies, offshore entities, and nominee arrangements
  3. Cross-border transactions complicate sanctions screening with multiple jurisdictional requirements
  4. Many estate agents lack dedicated compliance resources and rely on manual checking processes

Sources: FATF Real Estate Guidance · UK National Risk Assessment·Estate agents guide

Solicitors and conveyancers

Law firms and solicitors act as gatekeepers to the financial system, handling client funds through trust accounts and facilitating complex transactions. Their professional expertise can be exploited to structure arrangements that obscure the origins of illicit wealth.

  1. Client account funds create direct exposure to money laundering through layering of transactions
  2. Formation and management of trusts, companies, and partnerships can be used to obscure beneficial ownership
  3. Legal professional privilege creates tension between confidentiality obligations and reporting duties
  4. Conveyancing, corporate transactions, and wealth management present distinct risk profiles

Sources: SRA AML Guidance · Research: lawyers and money laundering risk·Solicitors and conveyancers guide

Accountants and auditors

Accountants are involved in company formation, financial reporting, tax advisory, and transaction structuring, all of which can be exploited for money laundering. Multiple supervisory bodies oversee the sector with varying expectations.

  1. Company formation and registered office services can facilitate the creation of shell companies for laundering
  2. Advisory role on tax structuring and financial planning can be abused for layering illicit funds
  3. Auditing functions may fail to detect indicators of financial crime without adequate training
  4. Fragmented supervision across HMRC, professional bodies, and sector-specific regulators

Sources: HMRC AML Supervision·Accountants and auditors guide

Trust and company service providers

TCSPs are at the heart of beneficial ownership risk. Their core services, which include entity formation, nominee directorships, and registered office provision, can be exploited to create opaque ownership structures across multiple jurisdictions.

  1. Entity formation services are directly linked to the creation of vehicles for ownership obfuscation
  2. Nominee services create layers between the true controller and the entity, complicating identification
  3. Multi-jurisdictional operations require screening against multiple sanctions regimes simultaneously
  4. Complex corporate structures with multiple layers make beneficial ownership identification difficult

Sources: FATF TCSP Guidance · Research: corporate vehicles and money laundering·Trust and company service providers guide

Dealers in precious metals and stones

Precious metals and stones are portable, high-value, and globally tradable, making them attractive vehicles for value transfer and money laundering. The sector's cash-intensive nature and global supply chains add further complexity.

  1. High-value portable assets can be used to transfer value across borders without detection
  2. Cash-intensive sector with limited transaction traceability in parts of the supply chain
  3. Global supply chains with exposure to conflict zones, smuggling routes, and informal markets
  4. Threshold-based regulations mean some transactions fall just below reporting requirements

Sources: FATF Precious Metals Guidance·Dealers in precious metals and stones guide

Art market participants

The art market's opacity, subjective valuations, and tradition of private sales make it attractive for money laundering. The EU's 5th AML Directive brought art dealers above certain thresholds under AML obligations for the first time.

  1. Opaque valuations allow artificial inflation or deflation of prices to disguise fund movements
  2. Private sales and intermediary arrangements can obscure the identity of buyers and sellers
  3. Freeport storage enables assets to be held outside national jurisdictions indefinitely
  4. Limited industry-wide standards for due diligence and customer identification

Sources: EU 5th AML Directive provisions·Art market participants guide

Letting agents

Letting agents are increasingly subject to AML regulations. Rental payments can be used for layering illicit funds, and both landlords and tenants may be sanctioned individuals or PEPs requiring screening.

  1. Rental payments from overseas accounts can be used to launder funds through legitimate-looking transactions
  2. Both landlords and tenants require screening, doubling the compliance workload
  3. Long-term tenancies require ongoing monitoring as sanctions lists change
  4. Limited awareness of AML obligations among smaller letting agencies

Sources: UK Money Laundering Regulations·Letting agents guide

Cryptoasset businesses

Virtual Asset Service Providers face unique AML challenges due to pseudonymous transactions, cross-border operations by default, and a rapidly evolving regulatory landscape. FATF's Travel Rule and the EU's MiCA regulation are reshaping compliance requirements.

  1. Pseudonymous nature of blockchain transactions requires robust customer onboarding screening
  2. Cross-border operations by default require compliance with multiple sanctions regimes
  3. Rapidly evolving regulations including FATF Travel Rule, EU MiCA, and national VASP registration
  4. DeFi, privacy coins, and mixing services create additional screening challenges

Sources: FATF Virtual Assets Guidance · Research: AML in the crypto sector·Cryptoasset businesses guide

High-value dealers

Dealers in luxury vehicles, yachts, watches, and other high-value goods face AML obligations when accepting cash payments or payments above regulatory thresholds. These goods are portable stores of value attractive for money laundering.

  1. Cash-intensive transactions for luxury goods above regulatory thresholds trigger AML obligations
  2. International clientele with complex or undisclosed sources of wealth
  3. Portable goods can be easily transported across borders and resold in secondary markets
  4. Trade-based money laundering through mis-invoicing and over-valuation of goods

Sources: Research: trade-based money laundering·High-value dealers guide