From 14 May 2025, letting agents are now subject to financial reporting obligations. The Office of Financial Sanctions Implementation (OFSI) has added Letting Agents to the list of ‘relevant firms’ under financial sanctions regulations. Additionally, High-value dealers (HVDs) and art market participants (AMPs) also become relevant firms from the same date.

Letting agents should note that the reporting obligations apply irrespective of the value of any rental agreement. 

The guidelines set out by OFSI state that

“Under the reporting obligations, a relevant firm is required to report to OFSI as soon as practicable if it knows or has reasonable cause to suspect that a person (i) is a designated person; or (ii) has committed a breach of financial sanctions regulations. Where the designated person is a customer of the relevant firm, the relevant firm must also report to OFSI the nature and amount or quantity of any funds or economic resources held by it for the customer at the time when it first had the knowledge or suspicion. 

However, a relevant firm is only required to report this information to OFSI if the information or other matter on which its knowledge or cause for suspicion is based came to it “in the course of carrying on its business.” For letting agents, “in the course of carrying on its business” is defined as in the course of carrying out “letting agency work”.”

High-value dealers (HVDs) on the other hand only become a ‘relevant firm’ when receiving a cash payment (or linked payments) of at least 10,000 euros in total. This does not include bank transfers or digital payments. A ‘high-value dealer’ is a firm or sole trader that trades in goods (some of which have already triggered inclusion on the list previously, such as those who deal in gold and silver, for example. Any high-value goods may trigger this threshold including wine and spirits.

A ‘high value dealer’ is defined in sanctions regulations as a firm or sole trader that by way of business trades in goods (including an auctioneer dealing in goods), when the trader makes or receives, in respect of any transaction, a payment or payments in cash of at least 10,000 euros in total, whether the transaction is executed in a single operation or in several operations which appear to be linked. This refers to physical cash only and does not include bank transfers or digital payments.

An art market participant (AMP) is defined in sanctions regulations as “a firm or sole practitioner who is registered or required to register with HMRC as an art market participant under the Money Laundering Regulations (pursuant to regulations 56(5) and (6) of the Money Laundering Regulations)”.

An art market participant’s financial sanctions reporting obligations will apply in relation to ‘information or another matter’ that comes to it “in the course of carrying on its business” which means either when it:   

“trades in, or acts as an intermediary in, the buying or selling of works of art, where the transaction value (or the value of a series of linked transactions) is 10,000 Euros or more; or stores works of art where the value of the works of art so stored for a person, amount to 10,000 Euros or more.”  

One exception is where the art is “created by, or is attributable to, a member of the firm or the sole practitioner”.

The full guidance is here.