Audit and compliance first, letting agent second

Short answer

Harvey W James is an audit and compliance company first, and a letting agent and property-management company second. That ordering is deliberate. Under the Renters' Rights Act 2025 the cost of a compliance miss is higher than the cost of the compliance itself, and most agents still run the old annual-check model. We run a continuous one. This post explains what that looks like in practice and why we have built our partner stack around it.

What "continuous compliance" actually means

Compliance, for a letting agent, is a list of statutory duties. The Money Laundering Regulations 2017 require ongoing customer due diligence on landlords. The Immigration Act 2014 requires Right-to-Rent checks on every adult tenant, with periodic re-checks where a document is time-limited. The borough-licensing regime requires a property to hold the correct licence for the relevant scheme at every point during its let. The deposit-protection regime requires registration with an approved scheme within thirty days of receipt. The client-money-protection regime requires segregated accounts and a registered scheme.

There are two ways to operate that list. The old way is annual: identity verified at onboarding, AML run on file, Right-to-Rent ticked at move-in, licensing checked when the landlord asks, deposit registered manually each time, client account reconciled at month-end. The audit trail is built up by staff who remember to do it.

The continuous way runs the same checks as a standing posture against live data. Identity verification re-runs whenever a document expires or a status changes. AML, PEPs and Sanctions screening cross-references the landlord population against live registers, not against a screenshot taken at onboarding. Borough-licensing intelligence flows in as schemes are gazetted, not when the landlord asks. Deposit registration is automatic on tenancy start. Client accounts reconcile in real time. The audit trail is built up by the platforms, not by the staff.

The two models do the same checks. They produce very different audit trails. Under the Renters' Rights Act 2025, the audit trail is the thing landlords need most, because the compliance window has extended from the move-in event to the life of the tenancy.

The LettsPay continuous pipeline

The Money Laundering Regulations 2017 obligations on a letting agent are deceptively complex. The headline duties are customer due diligence on landlords at onboarding and ongoing monitoring thereafter. "Ongoing monitoring" is the part most agents do badly. The annual-check pattern — pull a screenshot of the register once a year, file it, move on — produces an audit trail that is only as fresh as the last refresh. If a landlord's status changes in March and the next annual check is in November, an agent operating that pattern carries eight months of stale compliance.

LettsPay sits at the centre of our compliance stack and runs identity verification, AML screening, and PEPs and Sanctions screening as a continuous pipeline. When a landlord is onboarded, LettsPay runs the full identity check. From that point on, the pipeline cross-references the landlord population against live PEPs, sanctions and identity-document registers, and surfaces any change the same week. If a landlord's status changes after onboarding, we hear about it. We do not wait for the next annual review. The platform won Accounting Tech at the Fintech Awards 2024 and PropTech of the Year 2025 — signals that the category sees the embedded-banking-plus-continuous-compliance model as the direction of travel, not an outlier.

The supervisory framework is the Money Laundering Regulations 2017. Our supervisory body is Propertymark, which audits our compliance with those regulations as part of our membership. The audit trail from LettsPay — what was checked, when, with what result, and what action followed — is the evidence we hold against that supervisory framework. It is queryable. It is contemporaneous. It does not depend on a member of staff having remembered to run the check.

LettsPay also runs our client-payments pipeline, which is the second leg of the audit story. Real-time reconciliation of rent collected from tenants, rent paid to landlords, NRL withholding to HMRC for overseas landlords, and supplier payments to contractors all flow through the same platform that holds the compliance record. The pay record and the compliance record are not separated by a staff-mediated handoff.

The architecture underneath that pipeline is what makes it bankable. LettsPay's banking partner is Griffin, a UK bank authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority. Every landlord we manage holds funds in their own ring-fenced digital wallet at Griffin, individually FSCS-protected up to one hundred and twenty thousand pounds — the protection is per landlord, not pooled across the agency. Client Money Protection — the separate scheme that pays out if an agent misappropriates client funds — sits on top, with our CMP membership paid by LettsPay via Client Money Protect. The compliance posture is enforced by the platform: client money is segregated, named to the landlord, FSCS-protected, and reconciled in real time. None of that depends on a member of staff doing the right thing every day.

Kamma and the borough-licensing problem

The hardest compliance area for a London landlord is property licensing. Local-authority licensing schemes — selective licensing, additional HMO licensing, mandatory HMO — are introduced, expanded, expired and re-introduced on borough-by-borough timelines that the landlord rarely tracks. A property that did not need a licence at instruction can need one twelve months later if the borough adopts a new scheme. The penalty for letting an unlicensed property in scope of a scheme is steep, retrospective, and lands on the landlord.

The annual-check model handles this badly. A staff member checks the borough register once a year, files the result, moves on. If a scheme is introduced in February and the next check is in November, the property is in nine months of unwitting non-compliance. Justice for Tenants reports that ninety-eight per cent of Rent Repayment Order claims against unlicensed properties succeed at tribunal — meaning a tenant who later discovers the property was unlicensed during their tenancy can recover up to twelve months of rent paid.

Kamma monitors the licensing position on every property we manage as an API-connected live data feed. Kamma's platform tracks scheme changes across London. When a scheme is introduced that affects one of our managed properties, the change surfaces in our systems the same week. We action it — apply for the licence, advise the landlord, update the audit trail — at the point the change happens, not at the point someone next remembers to look. Where the action is to apply for a new licence, Kamma's Applications service handles the submission end-to-end on the landlord's behalf, so the audit trail of the application itself sits in the same platform that flagged the need for it.

The coverage that makes this work is wider than the London-borough story suggests. Kamma has tracked over three hundred and fifty licensing schemes across the UK since 2017, with a new scheme arriving on average every eight days. An annual-check model is permanently several scheme cycles behind the real position; the continuous model collapses that lag to under a week.

The structural value of Kamma is that it eliminates the failure mode that costs landlords most: not the agent who forgets a check, but the agent who simply does not know a check is now needed. The borough does not write to the landlord to announce a new scheme. Kamma does write to us.

Goodlord Right-to-Rent and the audit trail

The Immigration Act 2014 makes Right-to-Rent the most procedurally demanding tenant-side compliance duty. Every adult tenant must be checked. The check must be against acceptable original documents or via the online Home Office service. A record must be retained for at least one year after the tenancy ends. Where a document is time-limited, a re-check is required before the document expires. A genuine, blameless mistake on a Right-to-Rent check can result in significant civil penalty.

The challenge is not running the check at move-in. The challenge is producing the audit trail at the point a Home Office spot-check arrives — sometimes years after the tenancy started.

We run Right-to-Rent through Goodlord, the same platform that handles the rest of our referencing and tenancy administration. The Right-to-Rent record sits inside the tenancy record. The same record captures the documents, the verification outcome, any periodic re-check, the references, the affordability check, the credit search, the tenancy agreement, the renewal record, and the rent-review notices. Single source of truth.

We have been API-connected to Goodlord for six to seven years. The platform serves around two to three thousand letting agents in the UK. Tenancies are drafted by Goodlord's solicitor panel — not by us in Word — which means the legal architecture under every tenancy that goes out under our name is the same legal architecture maintained by Goodlord's solicitors against current legislation. When the Renters' Rights Act 2025 came in, our tenancy template was already aligned.

Credas and the landlord side

The audit-and-compliance framing applies as much on the landlord side as on the tenant side. Tenants are checked at instruction for affordability and credit. Landlords are checked at instruction for identity, AML, PEPs and Sanctions, Source of Funds where relevant, and corporate-landlord beneficial ownership — the full identity-side compliance stack.

Credas is our primary provider for that stack. Credas is one of two providers in the UK certified against the UK Government's Digital Identity and Attributes Trust Framework (DIATF) as an Identity Service Provider, and the platform sits inside around sixty per cent of UK housing transactions either directly or through partners. Credas delivers positive identity outcomes in ninety-seven per cent of checks — the operational point being that continuous deep checks on every landlord do not slow onboarding to a halt, which is what makes the model workable in practice rather than only on paper. Credas covers biometric ID verification, AML, PEPs and Sanctions screening with ongoing monitoring, Source-of-Funds checks via open banking, and Know Your Business for corporate landlords. The Credas audit trail is the evidence we hold against the Money Laundering Regulations 2017 framework Propertymark supervises us against. The LettsPay continuous-monitoring layer described above sits on top: Credas does the initial deep checks, LettsPay re-flags status changes the same week.

The symmetry matters because under the Renters' Rights Act 2025 the landlord is more exposed to tenant-side defaults than under the previous regime, and the tenant is more exposed to landlord-side defaults too. Periodic tenancies mean the relationship is open-ended in both directions. A compliance regime that checks one side and not the other is doing half the job.

Why this matters under the Renters' Rights Act 2025

Two changes in the new regime push the cost of a compliance miss further out into the life of the tenancy.

First, periodic tenancies. There is no longer a fixed term that closes at twelve or twenty-four months. The same tenancy may continue for years. The compliance record attached to that tenancy needs to be current for years. An identity check done at the start of a 2026 tenancy that runs into 2030 has to still be defensible in 2030 — which means it cannot be the only check that has happened.

Second, the rent-review and end-of-tenancy mechanisms have been simplified in ways that put the audit trail front and centre. Section 13 is now the only rent-review mechanism. The tenant's two-month notice can be served at any point. A landlord cannot recover from a tenancy that should never have been granted by waiting for the fixed term to end, because there is no fixed term to end.

The implication is that the day-one decisions — who is the landlord, who is the tenant, is the property licensed, is the documentation right — keep mattering for the life of the tenancy. The audit trail keeps being read. The continuous model is built for that. The annual-check model is not.

There is also a more pedestrian point. The Renters' Rights Act 2025 has introduced new supervisory powers and new penalty levels across several of the underlying frameworks. The cost of being caught with a stale or missing check has gone up.

Where this leaves Harvey W James

We describe ourselves, when we describe ourselves accurately, as an audit and compliance company first, and a letting agent and property-management company second. That is not marketing language. It is an operational statement about how we have built the business. The technology stack we use was selected against that frame. The partners we work with were chosen against that frame. The way we train our staff is structured around that frame.

It is also the frame in which the rest of our claims — that we are London Rental Analysts, that we are new-build specialists, that we are RRA-ready — actually make sense. You cannot be a rental analyst without an audit trail to analyse. You cannot manage a new-build portfolio without the licensing, MVHR, F-Gas and Awaab's Law compliance regime running cleanly. You cannot offer landlords confidence under the Renters' Rights Act 2025 without the continuous-monitoring architecture that the new regime quietly assumes.

If you want to test any of this, ask. We can show you a sample audit log, a sample landlord statement, a redacted referencing record, or a redacted Kamma alert. Every claim on this page should be falsifiable.

Where to look next

• How your listing gets written — the listings-side sibling post; the advert framed as the first artefact of the audit trail.
• Audit and approval before the deduction — the deduction-side sibling post; director-level review between the contractor quote and the rent statement, completing the trilogy.
• Technology and Partners — the full operational stack page, organised by the job each layer does for a landlord.
• Landlords — the full landlord proposition, fees architecture, and service tiers.
• Overseas Landlords — the Non-Resident Landlord Scheme, MTD, and the YWC London LLP partnership.
• New-Build Specialists — the new-build compliance regime (HIU, MVHR, A/C, F-Gas).
• What annual new-build servicing actually costs — the Calibre worked-example post.

Sources

• Money Laundering Regulations 2017 (the supervisory framework for AML, PEPs and Sanctions checks).
• Immigration Act 2014 (the statutory framework for Right-to-Rent).
• Renters' Rights Act 2025 (the regime under which the audit trail keeps mattering for the life of the tenancy).
• LettsPay, Kamma, Goodlord, Credas, Tenancy Deposit Scheme, Propertymark.
• Harvey W James Essential Terms v2.1.5.

Disclaimer

This article describes the technology stack and compliance posture operated by Harvey W James Ltd at the date of publication. It is not legal, tax, or financial advice. Specific landlord-side or tenant-side compliance questions should be discussed with the relevant professional adviser. Statutory framework references — Renters' Rights Act 2025, Money Laundering Regulations 2017, Immigration Act 2014 — are provided for orientation; the operative legal text in each case is the statute itself. Cross-checked against Essential Terms v2.1.5.

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