What is an occasional transaction?
An occasional transaction is a one-off transaction that is not part of a business relationship (Money Laundering Regulations 2017, reg 3(1)). Most regulated firms must apply customer due diligence to an occasional transaction of £12,000 or more, including linked transactions that add up to that amount (reg 27(2), in sterling since 30 June 2026).
A business relationship, by contrast, is a business, professional or commercial relationship that you expect, when contact is first made, to have an element of duration (reg 4(1)). For a business relationship, CDD applies whatever the amount.
The UK thresholds since 30 June 2026
SI 2026/621 replaced the euro amounts in regulation 27 with sterling figures from 30 June 2026.
| Who | When CDD applies to a one-off transaction | Where |
|---|---|---|
| Most regulated firms | An occasional transaction of £12,000 or more, in one operation or several that appear to be linked | Reg 27(2) |
| Letting agents | Concluding a letting of land for a term of a month or more at a rent equivalent to £10,000 or more a month. CDD applies to both the landlord and the tenant | Reg 27(7A)–(7B) |
| High value dealers | An occasional cash transaction of £10,000 or more | Reg 27(3) |
| Casinos | £2,000 or more for certain gambling transactions | Reg 27(5) |
| Transfers of funds (for example money service businesses) | An occasional transaction that is a transfer of funds exceeding £800 | Reg 27(1)(b) |
CDD also applies at any amount if you suspect money laundering or terrorist financing, or doubt the identification documents you already hold (reg 27(1)(c)–(d)).
Source: MLR regulation 27, as amended by SI 2026/621; regulation 3; regulation 4.
What this means for your sector
- Estate agents: the estate agent is treated as entering a business relationship with the buyer as well as the seller, from the point the seller accepts the buyer’s offer (reg 4(3)). So both sides get CDD, regardless of the price. See AML for estate agents.
- Letting agents: the £10,000 a month rent test decides whether a letting is in scope. See AML for letting agents.
- Accountants and solicitors: most client work is a business relationship (ongoing or expected to last), so the £12,000 threshold rarely helps. A genuine one-off piece of work can be an occasional transaction. See AML for accountants and AML for solicitors.
Linked transactions
Splitting one payment into several smaller ones does not avoid the threshold. Regulation 27(2) counts a transaction “whether the transaction is executed in a single operation or in several operations which appear to be linked”. Deliberately breaking payments up to stay under a limit is known as structuring, and is itself a warning sign.
What a small firm should do
- Decide at first contact whether you expect an ongoing relationship or a one-off job, and record it.
- If it is a business relationship, apply CDD before you start, whatever the amount.
- If it is an occasional transaction, check the threshold for your sector and add up any linked payments.
- Apply CDD anyway if anything looks suspicious, and keep the records for 5 years after the transaction completes (reg 40).
Frequently asked questions
What is the occasional transaction threshold in the UK?
£12,000 for most regulated firms since 30 June 2026 (reg 27(2)). Different figures apply to letting agents (£10,000 a month rent), high value dealers (£10,000 in cash) and casinos (£2,000).
Do estate agents have a threshold for CDD?
No price threshold applies to estate agency work. The agent has a business relationship with both the seller and, once an offer is accepted, the buyer, so CDD applies to both.
Is a single job for a client always an occasional transaction?
Not always. If you expect, at the start, that the relationship will last, for example annual accounts or repeat instructions, it is a business relationship. Some services are treated as a business relationship even when they are one-off (reg 4(2)).
How AML Buddy helps
Whether the work is a business relationship or a one-off transaction over the threshold, AML Buddy lets you send your client one secure link for identity, address, sanctions, PEP and adverse media checks, with a timestamped PDF report. £5.40 per check inc. VAT, no subscription. See pricing.