Every estate agent dreads that phone call.
For Zoe Napier, it came at 4pm on a Friday, just before a bank holiday weekend. The caller was HMRC.
Five days.
That was how long Zoe had to produce AML policies, procedures and transaction records for inspection.
“It completely took over that bank holiday weekend,” she says. “Even when you believe you’re compliant, the fear kicks in. You can’t help thinking – why us?”
Short-notice HMRC AML inspections are common. They are designed to assess how compliance operates day to day, not how it looks after last-minute preparation.
The waiting period after an HMRC AML inspection call
After the initial call in May, nothing happened for months.
No follow-up.
No dates.
Just uncertainty.
“From May to September, you’re constantly thinking: are they coming? Have they forgotten about us? Should we be worried?”
This gap between notification and inspection is typical of HMRC AML audits. For estate agents, it creates prolonged uncertainty and pressure, particularly when compliance documentation needs to stand up to scrutiny at any moment.
Then, in October, HMRC arrived.
What HMRC reviewed during the AML inspection
The inspection lasted four and a half hours.
HMRC asked 47 detailed questions covering:
- AML policies and procedures
- Business-wide risk assessments
- Staff training and oversight
- Trusts and probates
- Escalation processes
- Historic transactions
This level of questioning is designed to test not just whether AML checks were completed, but whether decisions were consistent, reasonable and properly documented over time.
Why expert AML support matters during an HMRC inspection
Zoe did not face the inspection alone.
Smart Compliance attended the inspection on site with two qualified directors, supporting throughout.
“They were like an extension of our team. To HMRC, it felt like we were all one company.”
As a director, Zoe was able to answer most questions confidently. However, AML regulation is complex, and inspections often move quickly across technical detail.
“Where I might have hesitated or stumbled, they stepped in. That made a huge difference.”
HMRC inspections are practical and probing. Having experienced AML professionals present can help ensure that explanations, documentation and regulatory expectations remain aligned under pressure.
Random file checks and historic AML evidence
Towards the end of the inspection, HMRC randomly selected transactions from the previous 12 months.
The files were not chosen by the agency. They were selected by the inspectors.
“We didn’t choose the files – they did. That’s when the compliance packs really came into their own.”
HMRC reviewed full AML documentation for each transaction, including identity checks, source and proof of funds, escalation records and supporting evidence.
“HMRC were genuinely impressed. The packs were comprehensive, clear and easy to evidence.”
Random file checks are often where HMRC AML audits are passed or failed. Decisions that were sensible at the time must be supported by clear, accessible documentation.
“We did it well… but not well enough”
Before outsourcing AML, Zoe’s agency managed compliance in-house.
The inspection highlighted the limits of that approach.
“We realised we did it well – but not well enough. You also start to realise how many agents out there aren’t doing it properly at all.”
This is a common outcome of HMRC inspections. Many estate agents are trying to comply, but struggle with consistency, audit trails and evidencing decisions across a full year of transactions.
Today, every buyer and seller is processed through Smart Compliance. AML checks are handled consistently, decisions are documented, and audit-ready records are maintained.
The compliance guarantee and accountability under scrutiny
One element stood out during that first bank holiday weekend.
Smart Compliance’s financial guarantee.
“Knowing that if Smart Compliance completed the checks and HMRC later found an issue, the fine would be covered – that was a lifeline. For a small independent business, that reassurance is huge.”
During an HMRC AML inspection, accountability matters. Knowing who stands behind the work, and where regulatory risk sits, changes how agents experience scrutiny.
A message to other estate agents facing HMRC AML inspections
HMRC inspections are random. There is little warning.
Estate agents are expected to evidence up to 12 months of compliant transactions, risk assessments and documented decisions.
“You never know when that call is coming. The sooner you get started, the sooner you build that compliant year.”
Asked to describe Smart Compliance in one word, Zoe does not hesitate.
“Invaluable.”
Stories like Zoe’s show what HMRC AML inspections really test: not just whether checks were completed, but whether compliance can be evidenced clearly, consistently and confidently when scrutiny arrives.