Sanctions are restrictions the government sets to prevent financial crime, protect national security, and uphold international obligations. They can apply to people, businesses, or even entire countries. There are several kinds of sanctions, including:

 

- Financial sanctions - block access to assets, restrict financial services, or stop services from being provided to specific individuals or entities

 

- Trade sanctions - limit the buying and selling of goods with certain countries • Immigration sanctions - prevent named individuals from entering or staying in the UK

 

- Transport sanctions - control aircraft and ship movements associated with sanctioned entities

The key type to understand is financial sanctions, which freeze assets or block transactions with individuals or entities on the UK sanctions list.

From May 14, the government has decided that letting agents will be classed as a “relevant firm” under the UK’s sanctions regulations. This means you’ll have a legal obligation to report any confirmed or suspected sanctions breaches to the Office of Financial Sanctions Implementation (OFSI). To make these reports, you must check every prospective tenant and landlord against the UK sanctions list.

Regardless of size, all letting agents in the UK are affected, irrespective of whether you deal primarily with students or company lets, or work as a relocation agent. In other words, if you are a letting agent with one or 1,000 customers, you must comply with these regulations.

If you let a property to a sanctioned person or company—even by mistake—you could face serious consequences. These include fines (up to £1 million or 50% of the transaction value, whichever is higher), criminal prosecution, and reputational damage.

 

In September 2024, the Office of Financial Sanctions Implementation (OFSI) fined a company in the lettings sector £15,000 for breaching UK sanctions.

Yes, the regulations don’t distinguish between different types of tenants. All tenants who go through the referencing process must be screened.

Yes, you must check every landlord against the UK sanctions list and the named directors if the landlord is a company.

While the regulations specifically mention tenants and landlords, you should also consider screening guarantors, especially as they’re named parties to the tenancy. Referencing providers, like Goodlord, already include guarantors in their screening process.

Sanctions checks should happen after a landlord accepts the tenant’s offer but before the tenancy agreement is signed. In other words, the referencing stage is the ideal time to run a sanctions check. This ensures compliance without screening every single applicant in advance.

As early as possible in the onboarding process. The landlord is your client, so you should include sanctions screening in Know Your Customer (KYC) checks when they instruct you to let a property. You should carry out the check before progressing with the tenancy, ideally at the same time as verifying proof of ownership and identity. This ensures you remain compliant and can demonstrate you’ve assessed the risk before taking any payments or advertising the property.

No, the names on the sanctions list are publicly available, but you should ensure your privacy policy is up to date with all data processing activities you carry out. This ensures tenants and landlords know how their data will be used.

Legally, the rules only apply to prospective tenants and landlords. However, OFSI has suggested that sanctions checks should always have taken place. So, while not required, checking in-situ parties is advisable.

You must report it to OFSI immediately. The match could be a confirmed sanctions hit or just a strong suspicion. Either way, you’re required to act straight away.

Landlords must apply for a licence from OFSI to get permission. Until this happens, for:

 

- New tenancies - you must stop the transaction until OFSI reaches a decision

- Existing tenancies - you must stop accepting rental payments while you also can’t evict tenants until OFSI reaches a decision or gives you specific guidance

You should keep records of all checks:

 

- Throughout the tenancy

 

- A period after the tenancy ends, in line with your internal data retention policies

 

Without a record, it’s as if the check never happened.

Legally, no. However, to ensure you have complete coverage, Goodlord monitors applicants daily for 12 months after the initial screening. If anyone previously cleared is flagged during that time, you’ll be alerted automatically.

We continuously monitor tenants and guarantors against global Politically Exposed Persons (PEPs) and Sanctions lists for 12 months from the date of the original check.

You’ll receive a real-time notification alerting you to the change. Goodlord provides a clear, auditable report to help you assess and take any necessary next steps.

Not necessarily. Goodlord flags any matches and provides guidance, but it's up to you to assess the risk and decide on further action based on your compliance procedures.

Daily monitoring is included as part of the PEPs and Sanctions checks feature—there’s no additional fee.