There's a persistent bit of confusion in this industry. A lot of people assume that because a personal search firm handles property transactions, it must be part of the regulated anti-money-laundering world. It isn't. And acting as if it is — or worse, telling a client it is — gets the law wrong.
So let's clear it up. Where does the AML duty actually sit? Who's supervised, who isn't, and where does that leave your firm? Then the useful part: what you can genuinely offer a conveyancer client without overstating your role.
Are personal search firms part of the regulated AML sector?
No. Under the Money Laundering Regulations 2017, personal and property search firms are not a supervised sector. The regulated entities are conveyancers, supervised by the SRA or CLC, and estate and letting agents, supervised by HMRC. Doing searches does not put your firm in scope.
This matters because the assumption runs the other way so often. Someone hears "property" and "due diligence" in the same sentence and concludes the search firm must be registered somewhere for AML. It doesn't work like that. The duty follows the regulated activity — handling client money, acting in the conveyance, agency work — not the act of compiling a search from public records.
Your firm accesses council records, builds a CON29 and LLC1, and returns a report. That is not, in itself, a regulated AML activity.
Who actually carries the AML duty in a transaction?
The conveyancer carries it, and so do estate and letting agents — each under their own supervisor. The conveyancer must verify their client's identity and apply customer due diligence under SRA or CLC supervision. Estate and letting agents have separate obligations under HMRC. The search firm sits outside that supervised chain entirely.
HMRC supervises nine specific business types under the regulations. None of them is property search. The list runs to money service businesses, high value dealers, trust or company service providers, accountancy service providers, estate agency businesses, bill payment service providers, telecoms and digital and IT payment providers, art market participants, and letting agency businesses.
Read that list again and notice what's missing. Personal search firms appear on neither the HMRC list nor any professional-body list. There is no supervisor for them to register with for AML, because the activity isn't supervised. The supervision is real where it does apply: HMRC fined 254 estate-agency businesses over £1.6 million for anti-money-laundering breaches in a recent year — every penalty landing on a regulated agency, never on a search firm.
Who is AML-supervised?
| Party | Supervisor | AML-supervised? |
|---|---|---|
| Conveyancers (solicitors / licensed conveyancers) | SRA or CLC | Yes |
| Estate agency businesses | HMRC | Yes |
| Letting agency businesses | HMRC | Yes |
| Personal / property search firms | None | No — not supervised; may supply tooling |
The bottom row is the one that gets misremembered. A search firm is not an AML-supervised entity. It can supply tooling. That's a different thing.
Does supplying ID and AML tooling make a search firm "regulated"?
No. Offering identity and AML-check tooling as part of an order does not turn your firm into a supervised entity. You're providing a service that helps the conveyancer meet their duty. The regulatory obligation stays with them. Your firm doesn't acquire an AML registration requirement by selling a useful product.
This is the distinction worth being precise about, because it's easy to blur. There's a real difference between being a regulated AML business and supplying a tool that a regulated business uses. The first carries registration, supervision, and reporting obligations. The second is just commerce.
Get this wrong in a sales conversation and you've either frightened a client unnecessarily or, far worse, implied a legal status your firm doesn't hold. Neither is a good look.
"I've watched search firms tie themselves in knots over this. They think because they touch a property deal, they're somehow on the hook for money laundering. They're not. The duty's with the solicitor. Your job is to make their job easier — not to invent a regulator you don't answer to."
— Valerie Bennett, Personal Search Veteran · June 2026
How can a search firm add real value here?
By bolting the right checks onto the order, so the conveyancer's compliance file builds itself. A search firm can supply biometric identity verification, PEP and sanctions screening, bank account verification, and an SRA lawyer check alongside the search. The conveyancer still owns the AML duty — but the evidence lands in one place, at the point they're already instructing you.
Think about how a conveyancer's day actually goes. They've got the search to order, the client to verify, the other side's firm to confirm, source of funds to consider. If those checks come back as part of the same order flow, that's less switching between systems and a cleaner audit trail.
That's the constructive turn. You're not taking on a regulatory burden. You're making the regulated party's life easier and giving your firm a reason to be more than a search line on the invoice.
What checks are worth offering?
The useful set is fairly settled. Biometric ID confirms the person is who they say they are. PEP and sanctions screening flags politically exposed persons and listed individuals. Bank verification confirms account ownership for source-of-funds work. An SRA lawyer check confirms the firm on the other side is a real, regulated practice.
None of these obligations is yours. All of them help the people whose obligations they are. That's the whole pitch — and it's an honest one, because it doesn't pretend your firm is something it isn't.
What should you never say to a conveyancer client?
Never imply your firm is AML-regulated, supervised, or required to register with HMRC for money laundering. It isn't, on any of those counts. Saying so overstates your status and misstates the law. The accurate line is simple: you supply tooling that supports their AML duty; the duty itself remains theirs.
The honest framing is also the stronger commercial one. "We help your compliance file build itself" is a better offer than a muddled claim about being part of the regulated sector. Conveyancers know who supervises them. They'll trust a supplier who gets the regulatory picture right far more than one who fudges it.
When in doubt, point them to the gov.uk guidance on who needs to register and let the primary source settle it.
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