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Why sanctions checks are as vital as Right to Rent

Landlords in England must now manage two separate, overlapping compliance duties when onboarding tenants: statutory Right to Rent checks and sanctions screening. While one is firmly grounded in immigration law, the other relates to broader UK national security and financial crime controls - and both carry serious consequences if ignored.

Under the Immigration Act 2014, the Right to Rent scheme requires landlords to verify that tenants have a lawful right to reside in the UK before granting a tenancy. They need to either examine original documents in person or use the Home Office online checking service and retain dated records. Conducting these checks correctly provides a statutory excuse against civil penalties if a tenant is later found not to have the right to rent.

The Home Office’s updated code of practice explains that failure to comply can result in significant civil penalties - up to £5,000 per lodger and £10,000 per occupier for a first breach - with repeat breaches attracting even higher fines. In the most serious cases, landlords can also face criminal penalties, including unlimited fines or prison sentences.

Specific

Right to Rent checks also include specific procedures landlords must follow when checking digital or manual evidence and establishing follow up checks if a tenant’s immigration status is time limited.

While Right to Rent is a statutory duty, sanctions screening arises from a series of national laws designed to prevent the UK economy from being exploited by individuals or entities tied to terrorism, hostile states, money laundering or other prohibited activities. The Office of Financial Sanctions Implementation (OFSI) - part of HM Treasury - maintains the UK’s consolidated sanctions list, which identifies individuals and organisations subject to financial restrictions.

Since May 2025, new regulatory guidance clarifies that letting agents - and by extension landlords involved in tenant checks - must conduct financial sanctions checks on prospective landlords, tenants, guarantors and other adults who will live in the property as part of due diligence and anti money laundering (AML) obligations.

Sanctions checks are not yet a standalone statutory requirement in the same way as Right to Rent, but official guidance confirms that letting agents are legally required to check all clients, including tenants and landlords, against the UK’s sanctions list as part of their reporting obligations under the Sanctions and Anti Money Laundering Act 2018 and related regulations.

Prospective

In practice, this means landlords should screen prospective tenants and guarantors against the UK sanctions list before entering into tenancy agreements - ideally using the official government list directly or via tenant referencing providers that include sanctions screening as part of their checks. The UK Financial Sanctions List is publicly accessible and updated regularly, making it possible for landlords to conduct checks themselves if they choose.

Although sanctions screening is separate from Right to Rent, many landlords combine these checks into a single pre tenancy process to streamline compliance and reduce risk. Keeping clear, dated records of both sets of checks can help demonstrate diligence if challenged by inspectors, referencing agencies or during regulatory reviews.

Advise

Professional bodies advise that landlords need to build anti money laundering checks including sanctions screening into their standard pre tenancy due diligence. Landlords must be aware of AML obligations and risk indicators, as explained in LandlordZONE’s guidance on money laundering risks and due diligence for private landlords.

With the sanctions list changing frequently in response to global events, landlords would be advised to check this when vetting new tenants and renewing tenancies.

Tags:

sanction checks
Right to rent
UK landlord

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