David Pett, solicitor and risk and compliance director at MJP Conveyancing, explores the areas regulators will focus on in their crackdown on money laundering in the coming year, and shares advice on how conveyancers can stay compliant.
Property remains one of the most attractive routes for criminals who want to move and disguise illicit wealth. As we move into 2026, the techniques used by those involved in money laundering are becoming more sophisticated, and the expectations placed on conveyancers are rising just as quickly.
The days when anti-money laundering compliance meant simply collecting a passport and a utility bill are long gone. Regulators now expect a questioning mindset, a clear understanding of how modern financial crime works, and strong evidence that firms are prepared to say no when a transaction does not feel right.
The rise of sanctions
Sanctions are a prime example of this changing landscape. They are no longer limited to a small group of high profile individuals. Instead, entire sectors and regions can be caught by national and international sanctions regimes. In addition, there is a growing use of secondary sanctions, where you can face real risk even if your own client is not named, but is connected to a party that is.
For conveyancers, this means that any overseas element in a transaction deserves careful attention. Where funds, companies or business interests have links to higher risk jurisdictions, it is essential to check sanctions lists carefully, to understand the nature of those connections, and to document clearly why you concluded it was appropriate to proceed.
Digital assets
Cryptoassets present another significant challenge. More clients are turning digital assets into conventional funds and using the proceeds to buy property. By the time the money appears in your client account, it may look just like any other bank transfer. However, regulators will increasingly expect firms to look behind the transfer and understand how the wealth was generated.
In practice that means asking to see transaction histories, wallet records and details of the exchanges used, and being prepared to walk away if the client cannot provide a clear and coherent explanation. The use of privacy tools or mixing services, which are designed to break the audit trail, should be treated as a serious warning sign.
AI and remote onboarding: the perfect storm
The rapid development of artificial intelligence has transformed identity fraud. High quality fake documents can now be generated quickly and cheaply, and deepfake technology allows a criminal to impersonate another person with alarming realism during a video call.
At the same time, remote onboarding remains popular with clients and firms. This combination creates a perfect environment for sophisticated identity fraud. In 2026, conveyancers will need to rely on more than a quick video call and a scan of a passport. Robust identity solutions that include biometric checks, chip reading and liveness testing will become increasingly important, and staff at every level will need training on the limitations of traditional checks and the signs that something may not be genuine.
Complex corporations
Complex corporate structures continue to be a favoured tool for obscuring beneficial ownership. Instead of a straightforward company in a single jurisdiction, we now often see chains of entities spread across several countries, involving trusts, nominees and opaque holding vehicles.
The purpose is clear, to make it difficult to see who really controls the funds. Regulators expect conveyancers to push through these layers until they reach a real person, and then to understand how that person acquired their wealth.
Where an apparently modest property purchase sits behind an elaborate offshore structure, or where there are last minute changes to shareholders or directors just before completion, those factors should be treated as significant risk indicators, not as administrative quirks.
New routes for financial crime
The growth of environmental and energy related investment schemes has created a new route for financial crime. Carbon credits, green bonds and renewable energy projects can all provide a respectable front for the movement of large sums of money. Many such schemes are entirely legitimate, but some are not.
Funds arriving from an unfamiliar environmental product or an overseas energy project should not simply be accepted at face value because the label sounds positive. Conveyancers need to ask basic questions about what the scheme actually does, how the client is involved, and whether independent information supports the story being given. If the explanation is long on marketing language and short on substance, the risk is likely to be higher.
The role of intermediaries
There is a growing reliance on intermediaries and third parties. Clients may be introduced by consultants, business fixers or informal advisers who present themselves as trusted professionals. While some introductions are entirely genuine, others are designed to keep the real client at a distance. The key point is that the duty to carry out due diligence lies with the firm, not with the intermediary.
Conveyancers should insist on speaking directly to the beneficial owner at an early stage, apply the same checks regardless of who introduced the work, and be especially cautious where an intermediary resists sharing basic information or seeks to control all communication.
Cross-border transfers
Modern payment systems have made rapid cross-border transfers both easy and cheap. Criminals exploit this by moving money quickly between multiple accounts and jurisdictions, often in the days or even hours before completion.
For conveyancers, this means that it is no longer enough to see that the balance has arrived. You must also look at the route the money has taken. Multiple payments from unrelated overseas accounts, sudden large sums from countries that do not match the client’s profile, or complicated funding paths when a simple one would do, are all reasons to pause and ask further questions.
Political connections
Another area of increasing attention is clients who have links to conflict zones or public office. Even when a person is not formally classified as a politically exposed person, their connections may still present heightened financial crime and reputational risk. Work with such clients should trigger enhanced due diligence.
You should understand their role, their income and their background in more detail, and you should record your assessment and reasoning clearly on the file. Regulators will not expect you to refuse every such instruction, but they will expect to see that you thought carefully and critically about it.
The growth of cybercrime
Cybercrime continues to grow, and property is an attractive way for criminals to store and legitimise the proceeds of online fraud, scams and ransomware attacks. This often presents itself as a very young client with significant wealth, or a client whose story about their business or investment success is extremely vague. Funds may arrive from modern digital platforms or payment services that do not match the client’s stated occupation or history.
Once again, the presence of a bank transfer does not mean that the underlying source of wealth is acceptable. Conveyancers should be prepared to probe, to ask the client to explain their success in clear and simple terms, and to document any concerns and the steps taken in response.
The enhanced role of the FCA
Perhaps the most significant regulatory change on the horizon is the increasing involvement of the Financial Conduct Authority (FCA) in areas that have previously been viewed as the domain of the legal regulators alone. The FCA brings a culture of intensive, risk based supervision.
For conveyancers, that is likely to mean greater emphasis on firm wide risk assessments, clearer evidence that policies are actually applied in practice, and closer scrutiny of records. Files will need to show not only what checks were completed, but why particular decisions were made, especially where there was some level of risk but the firm chose to proceed. At the same time, the overall enforcement environment is becoming tougher, with more inspections, more detailed audits and more meaningful penalties for firms that fall short.
All of this points in one direction. In 2026, anti money laundering and sanctions compliance cannot be treated as a box ticking exercise.
Conveyancers need to cultivate a culture in which people feel able to ask questions, to challenge unusual features of a transaction, and to escalate concerns without fear of criticism. Investment in modern technology, good quality training and clear internal reporting lines is essential, but so too is a mindset that recognises that saying no is sometimes the safest and most professional outcome.
By combining curiosity, careful documentation and the courage to act on their concerns, conveyancers can protect their firms, their clients and the wider integrity of the property market in what promises to be a demanding year.
About the author
David Pett is a solicitor and the managing director and founder of MJP Conveyancing. Passionate about using technology to streamline property transactions, he also leads the firm’s Risk and Compliance team. David is committed to driving progress in the property sector and ensuring practices remain robust and forward-thinking.
