On 29th May, Bright Line Law published an article by Jonathan Fisher QC which discusses the circumstances of 6 unusual money laundering cases arising in the context of estate agents and the UK property market. These included 3 cases involving PEP. It mentions that the NCA considers the number of suspicious activity reports made by estate agents to be “relatively low” and HMRC has been imposing substantial fines on estate agents for failing to comply with anti-money laundering legislation. The most serious contravention will involve a failure to spot suspicious circumstances, and the message is clear. Property professionals must keep their eyes peeled not only for obvious signs of money laundering but also for more subtle indications.