When HMRC arrives — what do you produce?

HMRC inspections of estate agencies typically cover six areas: the firm-wide risk assessment (is it specific to your business or a generic template?), customer due diligence records (do they show the reasoning behind risk assessments or just the documents collected?), the SAR decision log (decisions not to report are as important as reports made), training records (who was trained, when, on what), sanctions screening records, and listing decision documentation.

HMRC inspectors ask to see all of these on arrival — while you are handling live transactions. The most common enforcement trigger is not the absence of a process but the absence of a record showing the process was followed. A generic risk assessment, undocumented CDD reasoning, or a SAR log that only captures reports made (not decisions not to report) are all common inspection findings.

Most estate agencies we speak to have a process. They conduct CDD. They screen against sanctions lists. They make SAR decisions. But the reasoning behind those decisions — why this client was assessed as standard risk, why this transaction proceeded, why a SAR was not filed — is either not recorded or exists in a form that would take days to compile.

HMRC does not give advance notice. One morning there is a letter. From that moment you are expected to produce everything — at pace, while handling live transactions, in a format that demonstrates your process was followed consistently.