New RICS Guidance on Money Laundering and Financial Crime
- Jen Lemen
- Oct 7
- 6 min read
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What is this blog about?
In this week’s blog, we look at the new RICS Professional Standard Countering Financial crime, Bribery, Corruption, Money Laundering, Terrorist Financing and Sanctions Violations (2nd Edition). This replaces the former 1st Edition Professional Standard, which had a slightly different but similarly long title.
This is essential reading for all RICS APC and AssocRICS candidates, as well as qualified Chartered Surveyors. It relates specifically to the Ethics, Rules of Conduct and Professionalism competency and is something that you need to be thinking about when acting for any new or existing client.
You can read the full Professional Standard on the RICS website. You can also check out a list of helpful red flags published by RICS here.
When does the Professional Standard take effect?
17 December 2025.
Where does the Professional Standard apply?
Everywhere – it is a Global Professional Standard. As a result, you need to be aware of relevant local, regional, national and global legislation relating to these topics.
Where legislation contradicts the Professional Standard, legislation will always take precedence.
How is the Professional Standard structured?
The Professional Standard is structured as follows:
Glossary – this is worth reading to ensure you understand key terminology used elsewhere in the guidance. These are also terms that you could be asked about in your RICS APC final assessment interview
Introduction
Bribery and corruption
Money laundering and terrorist financing
Sanctions
Other considerations
Do I have to follow the Professional Standard?
Yes!
Professional Standards provide requirements for RICS members and Regulated Firms to follow. Requirements are mandatory where the word ‘must’ is used and are best practice where the word ‘should’ is used.
Why has the guidance been published?
Real estate can be used to launder illicit funds, thus surveyors are in a pivotal position to identify potential red flags and alert the relevant authorities. This helps to promote trust in the profession and protect the public interest.
The RICS recognise that the markets in which we operate are dynamic and new risks relating to money laundering and corruption are evolving quickly. The new Professional Standard deals with and provides guidance to surveyors on these new areas of risk.
As RICS state in the guidance;
‘Financial crime is not an abstract risk. When professionals uphold high standards, stolen public funds are harder to launder and communities are less exposed to speculative surges powered by secrecy. When they do not, corruption and financial crime spread, and the costs are borne by the many so that a few may profit. The profession cannot be a bystander’.
Taken seriously and applied consistently, we can be part of the solution and not part of the problem.
What does the Professional Standard say about bribery and corruption?
RICS state the following mandatory requirements for Regulated Firms:
Not offer or accept bribes
Comply with legislation
Report any suspicious activity
Carry out regular and appropriate written risk assessments and due diligence
Document compliance with the Professional Standard
RICS then provide additional guidance on best practice to meet the mandatory requirements, such as having written anti-bribery and corruption policies, a gift & hospitality register, staff training, appointed money laundering office, staff code of conduct and due diligence on suppliers.
RICS state the following mandatory requirements for members:
Not offer or accept bribes
Have appropriate knowledge to comply with the Professional Standard
Report any suspicious activity
RICS then provide additional guidance on best practice to meet the mandatory requirements, such as declaring any gifts & hospitality, attending training, adhering to employer policies and taking a leadership role in relation to compliance if in senior management.
RICS state the following mandatory requirements for Regulated Firms and members:
Be aware of risks faced in regular business activities
Plan how to deal with challenges if operating in higher risk sectors or jurisdictions
As with most areas of RICS regulation, the nature of how Regulated Firms and members deal with these challenges needs to be risk-based and appropriate
What does the Professional Standard say about laundering and terrorist financing?
RICS state the following mandatory requirements for Regulated Firms:
Exercise caution and not facilitate or be complicit in money laundering or terrorist financing
Have systems and training in place
Report any suspicious activity
Comply with relevant legislation
Must avoid tipping off
Retain confidential personal information to comply with relevant legislation
Must not ignore red flags
Carry out regular risk assessment and terminate business relationships where necessary
Carry out standard or enhanced due diligence (in high risk cases), including the identity of the client (Know Your Clients, or KYC, checks)
Use reliance only where the third party information is reliable
Understand the nature of the client and transaction
Examine the supply chain appropriately
Document compliance with the Professional Standard
Agree written terms of engagement with any third party compliance check services
Understand emerging asset classes and digital currencies
RICS then provide additional guidance on best practice to meet the mandatory requirements, such as having written policies, staff training and conducting checks on both buyers and sellers.
RICS state the following mandatory requirements for members:
Not facilitate or be complicit in money laundering or terrorist financing
Must not ignore red flags
Report any suspicious activity
Assess each transaction to agree controls and investigative measures
Avoid tipping off
RICS then provide additional guidance on best practice to meet the mandatory requirements, such as undertaking training, complying with employer policies, keeping suspicious activity reports confidential and taking a leadership role in relation to compliance if in senior management.
What does the Professional Standard say about sanctions?
RICS state the following mandatory requirements for Regulated Firms:
Not engaging in and implementing systems and controls to avoid engaging in business transactions with specially designated nationals (SDNs)
Providing staff training
Carry out regular risk assessment
Carry out adequate due diligence screening
RICS state the following mandatory requirements for members:
Carry out appropriate checks to avoid carrying on business relationships with SDNs
What other considerations does the Professional Standard deal with?
Customer due diligence (CDD) must be undertaken to verify the identity of clients, the validity of the identification documents provided and additional checks if the transaction or instruction is high risk.
Simplified due diligence (SCC) is acceptable in low risk situations where full CDD is not needed. Examples include where a client is a local council, registered charity or stock market listed company. HOWEVER, in the UK ‘applying SDD is no longer an automatic option in any situation and firms must be alert to red flags’.
Enhanced due diligence (EDD) is required in high risk situations.
RICS also discuss how firms can deal with electronic verification, outsourcing due diligence, reliance on checks, politically exposed persons (PEPs), compliance & ethics champions, codes of conduct, whistleblowing and AI.
If a Regulated Firm or Firm departs from the Professional Standard, then the departure must be recorded in writing with the reason.
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Stay tuned for our next blog post to help build a better you.
N.b. Nothing in this article constitutes legal, professional or financial advice.
