Anti-Money Laundering (AML) for mortgages refers to the rules and checks that lenders, brokers, and financial institutions must follow to prevent criminals from using mortgage loans to launder illegal money. These requirements are part of broader financial crime regulations.
1. Why AML applies to mortgages
Mortgage transactions involve large amounts of money and property, which makes them attractive for criminals who want to:
For example, someone might use illegally obtained money as a deposit or repay a mortgage quickly to clean the funds.
2. Key AML checks in mortgage lending
Customer Due Diligence (CDD)
Lenders must verify the borrower’s identity and understand who they are dealing with.
Typical checks include:
Source of Funds
Lenders must understand where the money for the deposit comes from.
Common acceptable sources:
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Salary savings
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Property sale
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Inheritance
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Gift from family
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Investments
Evidence may include:
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Bank statements
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Gift letters
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Probate documents
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Investment statements
Source of Wealth
If the transaction is large or unusual, lenders may ask how the borrower accumulated their overall wealth.
Example explanations:
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Long-term employment
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Business ownership
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Investments
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Property portfolio
Politically Exposed Person (PEP) Checks
Borrowers are screened to see if they are a Politically Exposed Person, meaning someone who holds a prominent public position.
PEPs require enhanced due diligence because they may have higher corruption risk.
Sanctions Screening
Applicants are checked against international sanctions lists to ensure they are not restricted individuals.
3. Ongoing monitoring
Lenders may continue monitoring if something unusual happens, such as:
4. Suspicious Activity Reporting
If a lender suspects money laundering, they must report it to authorities.
In the UK this is done through the National Crime Agency via a Suspicious Activity Report (SAR).
5. Main UK AML laws affecting mortgages
Mortgage AML checks in the UK come from regulations such as:
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Money Laundering Regulations 2017
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Proceeds of Crime Act 2002
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Financial Conduct Authority financial crime rules