August 25 2017
Agents need to conduct a money laundering risk assessment and conduct customer due diligence on buyers – that is a statutory duty that comes from the Regulations not HMRC.
The guidance HMRC has issued on the subject currently states that the buyer’s identity must be verified before the contracts are exchanged and so in theory agents have weeks, if not months, to obtain the appropriate ID.
In practice, if it is not carried out early in the buying process the chances of being able to do it diminish as time goes by.