How long must letting agents and accountants retain AML records?

Money Laundering Regulations 2017 regulation 40 requires regulated firms (letting agents, conveyancers, accountants, fintech / payment firms) to retain customer due diligence records for 5 years from the date the business relationship ends or the occasional transaction was completed. The clock starts at the end of the relationship, not the start of it. For letting agents this means 5 years from the end of the tenancy; for conveyancers 5 years from completion; for accountants 5 years from disengagement.

The 5-year minimum can be extended to a 10-year retention on written request by an enforcement authority (HMRC, the FCA, the National Crime Agency) where a specific investigation is in scope. In practice, firms either operate a 5-year default policy with selective extensions, or default to 7 years to absorb the extension headroom plus the ICO Subject Access Request reach-back period. The Stratum audit-cert PDF is built around a 7-year DDB TTL for this reason: it covers the regulator-extension window without further user action.

Records retained must include the customer identification documents, the screening results (sanctions / PEP / adverse-media match data + list versions), the source-of-funds evidence where required, the risk assessment performed, and any ongoing-monitoring outputs. The Letting Sector AML Guidance 2025 (LSAG-2025) reaffirms the 5-year floor and operationalises retention format expectations including timestamp + list-version stamping.

Source: Money Laundering Regulations 2017

Last updated 2026-05-09.