What is LSAG-2025 and how does it differ from LSAG-2018?
LSAG-2025 is the 2025 update to the Letting Sector AML Guidance — the HMRC-supervised industry guidance that operationalises MLR-2017 obligations for UK letting agents. It came into force May 2025 alongside the broader sanctions-screening rule. LSAG-2018 was the previous version, published shortly after MLR-2017 came into force.
Key differences in LSAG-2025:
- **Explicit PEP screening expectation.** LSAG-2018 mentioned PEP exposure as part of the broader risk-based approach; LSAG-2025 names PEP screening as a default expectation on every let, with the FATF Recommendation 12 categories (current PEP / former-within-12-months / family / close-associate) explicitly listed.
- **Adverse-media check on parties.** LSAG-2018 didn't require an adverse-media check; LSAG-2025 expects it as a defence-in-depth alongside the sanctions + PEP screen.
- **Beneficial-ownership for corporate landlords.** LSAG-2018 was light on this; LSAG-2025 explicitly references MLR-2017 reg 5(1)(a) and expects letting agents to walk the PSC tree on corporate landlords, identify UBOs at >=25% effective stake, and screen each UBO. This is §B of the new guidance.
- **Audit-trail format.** LSAG-2025 expects list-version timestamps on the screening evidence (i.e. the cert must record which version of the OFSI / UN / EU lists were screened against). LSAG-2018 was silent on this, which made post-fact audit fragile.
For letting agents implementing LSAG-2025: the Stratum letting-agent suite endpoint covers all four expectations (sanctions + PEP + adverse-media + PSC walk for corporate landlords) and binds the audit trail via a SHA-256 hash printed in the PDF footer.
Source: LSAG Guidance
Last updated 2026-05-06.