At this year’s BLG Conference, I had the privilege of chairing a panel on UK anti-money laundering in the property sector. The room was full, the conversation was frank – and at points, deliberately provocative. What follows is a recap of the key themes we discussed, but also my own view on where the industry stands and what needs to happen next.
The short version: the risk is already here, regulatory expectations are rising, and the tools to respond properly already exist. In many firms, the issue is no longer a lack of knowledge or technology. It is whether AML is being treated with enough urgency and discipline.
Let me start with some numbers: An estimated £11.1 billion of illicit funds has been invested in UK real estate over the last decade, making property the highest-risk AML sector in the country according to the UK National Risk Assessment. Another widely cited estimate suggests that £325 billion of dirty money flows through the UK economy every year, roughly 10% of GDP.
These aren’t abstract figures. In March 2026, 85 London properties were frozen by authorities in a single high-profile case involving illicit offshore funds. Regulators are watching: the SRA issued around 35 fines in 2025 totalling approximately £565,000, while the FCA’s total fines for the same period reached approximately £120 million.
And then came the October 2025 announcement: the FCA is to become the sole AML/CTF supervisor for professional services, replacing the SRA. That signals a significant shift in how the UK government intends to approach this area. The FCA is more focused on data, outcomes and evidence than many firms are used to and it is unlikely to be satisfied with a well-formatted policy document.
Our panel explored what the biggest risks look like in practice. The established vulnerabilities – politically exposed persons, sanctioned individuals, and high-value transactions – remain prominent, but two newer threats are gaining ground.
AI is increasingly being exploited as a tool for financial crime. Cryptocurrency is a growing blind spot, and conveyancers and law firms often lack the tools and the knowledge to identify when property is being purchased with the proceeds of crime laundered through crypto assets. Complex fund structures can also make source of wealth difficult to trace, with ownership and control often sitting behind several layers.
On the compliance side, the primary gap is around Source of Funds. Not just collecting documents needed to prove SoF, but actually understanding what you’re looking for, why you’re looking for it, and being able to articulate that clearly. Too many firms have built processes around paperwork rather than understanding, but simply having a policy is not the same as following it with purpose.
One of the more memorable moments came when Peter Ambrose – not a man known for pulling his punches – opened his contribution with: “I disagree with all of that.”
His position, which I think should be taken seriously, is that having seen around 30,000 transactions over his career, he couldn’t say with confidence whether any of them involved laundered money – and he argued that’s actually the point. Conveyancers are not financial investigators, and there has to be a line drawn.
The profession should of course conduct proper checks, use appropriate tools, and evidence their process – but they should not be expected to identify criminal behaviour. That’s not something they have been trained for and is beyond their professional mandate.
I have some sympathy with this. The burden placed on conveyancers has grown significantly in recent years, and the expectation that a busy solicitor should effectively operate as a financial crime analyst is not realistic. That said, “busyness” is unlikely to be a defence the FCA will accept.
For me, technology in AML should do three practical things. If it does them well, a firm is in a much stronger position:
Reduce friction. The discomfort of asking a client to explain where their savings came from is a natural human problem, and it hasn’t changed much in the years since I worked in frontline conveyancing. Good technology changes that significantly. A well-designed onboarding platform frames the request professionally, securely and in the client’s own time. That means the lawyer does not have to turn a sensitive compliance requirement into an awkward conversation and it means the relevant information is provided in a much more structured way and is evidenced.
Reduce noise. A single conveyancing file carries a significant AML workload: ID verification, PEPs and sanctions checks, source of funds, source of wealth… the list goes on. Done manually under time pressure, gaps, inconsistencies and files that do not evidence the work clearly enough inevitably appear.
Technology should handle the gathering, checking, flagging and recording of this information, so that when a trained legal mind steps in to make a judgement, they are working from information they have confidence in.
Continuous monitoring matters here too. A check at onboarding is only a single point in time, whereas client risk can change mid-transaction.
Provide proper assurance. The principle, reflected in the LSAG guidance, is that the job of these checks is not merely to confirm that someone of that name exists, but that the individual is genuinely who they claim to be.That is a meaningfully higher bar.
‘House hijacking’, where a property is fraudulently sold using forged identity documents, is a real and well-documented threat, and HM Land Registry has paid out millions compensating victims. Simply running a name through a database does little to prevent it, but Biometric ID checks paired with liveness detection, including solutions such as tmVerify, confirm not just that a passport looks real, but that the person holding it is the person in it.
The session closed with a sharp question from the audience, about whether the compliance burden should really sit with conveyancers at all, particularly where the buyer has a mortgage. Shouldn’t banks and lenders carry more of this?
The panel’s view was fairly direct: banks and lenders are not yet doing this consistently enough, but the deeper accountability gap sits with regulators and the UK government. They have placed an ever-increasing compliance burden on conveyancers while retaining significant regulatory ownership of the problem themselves. Financial Action Task Force (FATF) Mutual Evaluation Report of the UK, understood to be scheduled around August 2027, will require the government to demonstrate a credible plan, and it’s hoped that this will prompt action sooner rather than later.
Every firm should have the possibility of an FCA Readiness Audit on its mind. Not because a box needs ticking, but because the FCA is a fundamentally different kind of regulator. It will want to know transaction volumes, matters per month, screening outcomes, reporting metrics, and more. So, it won’t just be looking to see if a policy exists, but they work too.
The tools to do this properly are available. The challenge, and I say this having spent years working with firms across the sector, is largely one of urgency – or lack thereof. Firms that wait until the regulatory pressure becomes unavoidable will find themselves scrambling, while those who move now will be in a stronger position, with better evidence, clearer processes and more confidence in the way they serve their clients.
Ultimately, the distinction will not be drawn between firms that knew and firms that did not, but between those that acted and those that waited. Treating AML as a live operational discipline, rather than a policy exercise, is no longer a matter of good practice, and my expectation is that under the FCA it will very likely be the measure of compliance itself.
