About this form
Form D covers ongoing due diligence — the periodic review required where there is a continuing business relationship rather than a single transaction that completes and ends. It is the form most often forgotten, because the obligation it records has no single triggering event.
When you need it
- A client relationship continues beyond one transaction.
- You act repeatedly for a landlord, investor or corporate client over time.
- A periodic review of an existing relationship falls due.
How to complete it
- Review whether the particulars already on file remain current.
- Re-screen where the relationship has continued, and record the result.
- Reassess risk in light of anything that has changed — new parties, a different transaction profile, a change of control in a corporate client.
- Record the review even where nothing has changed. A file with no evidence of review looks identical to one where no review happened.
Common mistakes
- Treating due diligence as a one-off exercise completed at onboarding and never revisited.
- Carrying out a review informally, in conversation, without recording that it happened.
- Not re-screening a long-standing client precisely because they are familiar — familiarity is not a control.
- Missing a change of beneficial ownership in a corporate client between one transaction and the next.
- Letting the review lapse while the relationship is dormant, then resuming work on stale particulars.
Legal basis
Published by CEA as an annex to the Guide on the Estate Agents (Prevention of Money Laundering and Financing of Terrorism) Regulations 2021. Read the issuer’s guidance.
Questions
- How often is ongoing due diligence required?
- It is periodic and risk-sensitive rather than fixed to a single interval. Your agency’s compliance framework should set the cadence; CEA’s guide sets the expectation.
- Does a one-off sale need Form D?
- Not usually. Form D addresses a continuing business relationship, which a single completed transaction is not.
- Which version should I use?
- Use the 30 June 2025 versions. Forms from the superseded guide must no longer be used.