Property sourcing and AML: what should you check first?

Look at the work, not just the job title

HMRC describes estate agency work broadly. Its sector guidance includes businesses introducing buyers or investors to property deals, sometimes called property sourcing or deal packaging. Calling the activity consulting or education does not decide whether it falls in scope. Read current HMRC guidance and seek qualified advice about the actual activity you intend to undertake.

Check the registration position directly

Ask which supervisor covers the business and what its current status is. Use the official register and guidance rather than relying only on a website badge or company number. Check that the business details match the firm you are considering. A reference number, submitted application or payment is not evidence that HMRC has approved supervision.

Supervision is part of a wider process

Registration is not a guarantee that every action or transaction is compliant. The business needs appropriate controls for its actual work, including understanding customers and risk, keeping required records and following relevant reporting duties. This guide is not a full operational AML checklist and does not assess your proposed business.

Keep initial enquiries proportionate

You do not need to place identification papers, bank statements, tenant details or source-of-funds evidence in a public enquiry form. When a lawful engagement requires checks, agree a secure process and understand who is collecting the information, why and how it will be retained. A free education signup is not transaction due diligence.

What L&M’s pending status means

L&M’s application for HMRC AML supervision is pending, reference XTML00000222768. We do not describe it as approved, authorised or supervised. The public sourcing service remains waitlist only; no property matching, reservation or instruction is created by an enquiry. The free Academy offers general education, not permission to carry out regulated work.

Learn the sequence before offering a service

Start with the rules applying to the work you intend to do, confirm the registrations and professional advice required, then build the processes before offering that work. Revisit the official sources as requirements change. You can request the free L&M Academy to learn how property sourcing is organised; registration records a request and access is set up separately.

Official sources

• HMRC: estate agency registration guidance
• HMRC: sector-specific estate agency guidance
• HMRC: check a business’s supervision registration

Sources checked 5 October 2026. Consult the current guidance and qualified advisers for your circumstances.