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One in ten UK purchases now trigger enhanced AML due diligence

Overseas funds now feature in 10% of UK residential transactions, requiring enhanced AML checks. China replaces France in top five origin countries.

PBI NewsroomPublished Editorial direction by Jamie Adams and David Adams
Illustrative image: One in ten UK purchases now trigger enhanced AML due diligence

One in ten UK homebuyers now fund purchases with money originating overseas, according to analysis by client due diligence platform Thirdfort based on one million source of funds verifications it has processed. The figure implies that roughly 10% of residential transactions now trigger enhanced due diligence requirements under the Money Laundering Regulations 2017, with material consequences for conveyancers' workload allocation, transaction timelines and regulatory exposure.

Thirdfort reports the top five origin countries as India, USA, Hong Kong, Italy and China. China has entered the top five within the past two years, displacing France. The shift from European to Asian capital sources carries specific compliance implications, particularly as China and Hong Kong attract heightened scrutiny under current OFSI and FATF guidance on sanctions and beneficial ownership transparency.

Cash persists despite digital norms

Thirdfort's data shows 9% of buyers made more than ten cash deposits into purchase-funding accounts in the past six months, with a median deposit value exceeding £500. High cash deposits—defined as a median above £500—have declined from 9.47% of verifications in 2023 to 6.99% in 2026 to date, but remain present at a level inconsistent with broader societal trends toward digital payments.

The persistence of cash in high-value property transactions suggests specific buyer demographics—older sellers liquidating assets, cash-intensive businesses, or informal gifting within families—that conveyancers must risk-assess under MLR2017's requirement to understand the nature and purpose of a transaction. Declining cash use reduces aggregate risk but does not eliminate the need for capability to verify and document it.

Cryptocurrency remains negligible, involved in approximately 0.1% of buyer or giftor funds and stable since 2024. The figure may understate actual crypto exposure if digital assets are converted to fiat before reaching conveyancer accounts, but it does not currently justify significant resource allocation for most firms.

Compliance workload and resourcing decisions

MLR2017 requires enhanced due diligence on cross-border transactions, particularly where funds originate from jurisdictions with higher money laundering or sanctions risk. If one in ten transactions involves overseas funds, conveyancers face a material compliance workload that must be resourced, either through in-house expertise or third-party platforms like Thirdfort.

Reliance on vendor platforms does not transfer legal accountability. Conveyancers and estate agents remain personally and corporately liable for AML failures, and must satisfy themselves that due diligence procedures are adequate, current and applied consistently. The cost of non-compliance includes regulatory fines, personal sanctions under the Solicitors Regulation Authority or Property Ombudsman frameworks, and reputational damage.

The geographic concentration in India, USA, Hong Kong, Italy and China allows firms to build jurisdiction-specific risk profiles and tailor due diligence procedures. China and Hong Kong require particular attention given current sanctions regimes, beneficial ownership opacity and the UK government's scrutiny of capital flows from both jurisdictions. India and the USA typically present lower inherent risk but still demand evidence of legitimate source and lawful transfer.

Estate agents handling buyer inquiries should factor cross-border fund verification into their transaction timeline guidance. Enhanced due diligence routinely adds two to four weeks to completion schedules, and failure to set expectations early creates friction between buyers, sellers and conveyancers.

Data limitations and next steps

Thirdfort's analysis reflects only its own user base. The firm has not disclosed the geographic distribution of its clients, their average transaction value, or whether the sample skews toward London, the South East or higher-value markets where overseas funds are disproportionately concentrated. Without comparison to official data sources, the 10% figure should be treated as indicative rather than definitive.

Olly Thornton-Berry, Thirdfort co-founder, said: "Our data points to a market where most buyers are funding a purchase in ordinary, explainable ways." The characterisation is subjective and reflects a commercial interest in portraying the market as manageable, but the underlying data on cash decline and crypto negligibility is consistent with other industry signals.

Conveyancers should compare internal transaction data against Thirdfort's claimed patterns to assess whether their risk frameworks and resource allocation reflect actual exposure. Firms handling materially more or fewer cross-border transactions than the 10% benchmark may need to adjust compliance budgets, training programmes or referral criteria for complex cases.

Watch for HMRC or National Crime Agency releases on Suspicious Activity Reports or cross-border property capital to verify or challenge vendor claims. Any update to MLR guidance on enhanced due diligence for specific jurisdictions—particularly China or Hong Kong—would directly affect the transactions identified here. The SRA requires solicitors to confirm client identities and check the source of funds in legal transactions, and HMRC's guidance on source of funds and source of wealth clarifies when checks must be performed where a customer is involved.

Source notes

This article was written from the trade reporting below. The analysis and the PBI Take are ours; we have not independently verified the underlying facts.