This problem could be solved using a concept I published back in 2017 regarding entity verification and clearing to conduct financial transactions. In this case, the UK could certainly be doing more to screen real estate transactions and facilitating agents:

  • Creating and maintaining a centralized database of all persons and entities cleared to conduct business with domestic FIs or agencies;
  • Receiving and processing applications of persons and entities requesting to conduct business with domestic FIs or agencies;
  • Collecting Customer Identification Program (CIP) / customer due diligence (CDD) / enhanced due diligence (EDD) information; 
  • Updating databases with relevant information acquired through suspicious activity reporting, sanctions, criminal records, monitoring reports (transactions, updated data), etc.;
  • Granting special license for single-event permissions of non-cleared entities / persons;
  • Investigating and assessing beneficial ownership;
  • Investigating and assessing correspondent banks abroad;
  • Conducting periodic file reviews and risk assessments every 12 to 36 months (based on risk profiles);
  • Maintaining persons and entity risk ratings
    • Cleared: low risk / moderate risk
    • Cleared: high risk / permissible
    • Non-cleared: non-permissible