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Impersonation Fraud

Category: Compliance | Created: 2025-10-31 06:54:40

What is Impersonation Fraud?

In residential conveyancing terms, impersonation fraud occurs when a person pretends to be the true owner of a property in order to sell or mortgage it and steal the proceeds. It's a serious risk to residential conveyancers, and it's on the rise. Between 2020 and 2025 HM Land Registry prevented frauds against property with a total value of £194,000,000 but £59,000,000 of that relates to the most recent year, 2024/25. It is still extremely rare - of the more than 4,000,000 transactions processed by HMLR in 2024/25, only 86 were identified as fraudulent. Nonetheless the consequences can be crippling for homeowners and for the conveyancers that get duped.

What Sorts of Properties are Being Targeted?

There is no specific type - no property is "safe", but as with any criminal whose motive is to make money, the fewer crimes fraudsters have to commit the better chance they have to avoid getting caught, so to maximise their returns they will typically target reasonably high value, mortgage free properties. Mortgage free is important because you can easily establish the value of the property but not the amount of any debt secured against it, which the conveyancer is going to pay before handing over the remaining proceeds even if the fraud is successful. The fraudster will usually need to give an estate agent or a valuer access, so empty or rental properties are a safer bet. If a property rented the fraudster may pose as the landlord or an agent for the landlord, or may rent it themselves and pose as an owner occupier. Finally, properties with a sole proprietor will be an easier target, otherwise there will need to be more than one fraudster (one for each owner). Increased complexity equals increased risk of being caught.

What are the risks?

For clients, the risk is that they will either lose their property, have to make payments on a mortgage they never got the benefit of in order to keep it or in the best case, face an expensive and risky legal battle to get the property back free from incumbrances. From the conveyancer's point of view, the sale proceeds (or mortgage advance) is paid over to them on trust on terms that they will secure a charge in favour of a lender, or else pay the funds over to the person genuinely entitled to receive them. Even if a conveyancer has done nothing wrong therefore, the starting point is they have committed a breach of trust and are liable to the lender/owner to reimburse the stolen money. It is possible to  make an application for relief but existing case law suggests that might be unlikely. If it is to have any chance of success, the conveyancers will have to show that their due diligence process was flawless.

How Can Conveyancers Protect Themselves?

All conveyancers need to be aware of the "red flags" of impersonation fraud. Employers should provide regular training and should as part of the fee earner supervision process monitor to ensure that these flags are being spotted and properly considered. There should be a reporting channel and staff should be aware of it. So what are the red flags?

  • unencumbered properties - as mentioned above, these are targeted because the fraudster can easily establish the value, and so the amount of equity they can steal;
  • properties with old mortgages - less obvious, but fraudsters know what the red flags are and might try and slide under the radar by picking on a property with a mortgage that was taken out a number of years ago, especially if it is in an area that has experienced a sharp increase in property values since the mortgage was taken out;
  • the amount of capital being raised is above some arbitrary figure set by the firm - the fraud has to be worth it. Most fraudsters wouldn't risk their liberty for, say, £20,000. Most would for £2,000,000. Where to draw the line is up to each firm to decide but having a figure for staff to use may help them focus on the genuinely risky matters;
  • new or recent identity documents - fraudsters will sometimes obtain identity documents in the name of the owner. If they do, they will likely have been issued in the last 12 months. Once the fraud begins they will need to conclude it as quickly as possible;
  • bridging finance - fraudsters will sometimes use bridging loans for two reasons, first the lenders tend to be more relaxed in their due diligence and second, these cases are always urgent, which helps disguise any urgency to the transaction that would otherwise be unexplainable;
  • client has changed their name - a fraudster will sometimes change his or her name to match the property owner;
  • client has changed solicitors - if a fraudster has instructed a conveyancer who has become suspicious (of they think they have become suspicious) they will be quick to disinstruct and instruct someone else, with good reason. If a conveyancer has suspicions that something is off but hasn't positively identified any criminal activity then they will have no grounds to pursue and once disinstructed will simply close the file;
  • unexplained urgency - a fraudster's matter will usually be urgent because a) they want the cash; b) the longer the matter goes on, the more risky it is for them; and c) by putting pressure on the conveyancer to act quickly there is a better chance that corners will be cut.

Of course, no one these flags on their own are enough to arouse suspicion. The key is to look for a combination of them and if there is combination, look at each one and see if it be explained legitimately. To do that you will need to ask questions, and be robust, there is as yet no criminal property so there should be no tipping off concerns. If you are dealing with a fraudster you may well find that as you start asking questions they get nervous and disinstruct. Concentrate on these three areas:

The Funds

The first question might be what the capital raised is being used for. If it is for an onward purchase, ask for the details of the solicitors acting in that purchase so you can check with them. Offer to send the money to the solicitor directly (assuming they are in England of Wales). If it is for works, ask to see quotes etc. Borrowing money comes with a cost, so there will always be a purpose in mind when the mortgage is applied for. If the client can't explain that then you should be suspicious. 

The Person

Look at the person's name and age and the picture on the ID and see if it marries up. If the client has a Chinese sounding name and is in their 60s but the picture is of a 20 something Northern European, that's odd. Ask to see another form of photo ID (i.e. a passport, if the original ID is a driver's licence, or vide versa). If they are using a passport and it's recently been issued, ask to see their old one. Not everyone will keep their old passports but some do. 

The Property

The fraudster may be able to produce numerous pieces of evidence connecting them to the property but they are likely to be recent. Ask for evidence that is historic, such as the old deeds packet that the conveyancer may sent to the owner on completion of the purchase, or if the property is rented, old bank statements showing rental payments and the tenancy agreement for tenant at the time, or if it is owner occupied, bank statements showing council tax payments. You could obtain from Land Registry a copy of the transfer deed from when the property to compare the signatures against your client's. 

Make sure you carry out your OS1 search before exchange, a couple of days before if possible. That way, if the property owner happens to have subscribed to HMLR's property alert service, they'll be notified in time to contact you/HMLR before it's too late.

How Can Property Owners Protect Themselves?

There are a number of proactive steps that property owners can take to protect themselves and their properties:

  • Follow good cybersecurity practices - fraudsters used to go through their victims' rubbish looking for things like bank statements and utility bills to help them impersonate an owner. That may still happen, but more often nowadays the will get information by hacking email and social media accounts etc. So, be mindful of what you put on social media, choose strong passwords, update passwords regularly, don't use the same password for any two accounts etc;
  • Keep an eye on empty properties - fraudsters will often need access to the property to effect the fraud, so if you own any that are empty check them regularly for signs of unauthorised access. If you can't do that personally, get someone else to;
  • Vet tenants properly - a criminal might rent a property to enable them to pose as the owner, so be careful when choosing tenants. Consider enlisting the help of an experienced letting agent;
  • Keep your address for service up to date with Land Registry;
  • Use Land Registry's Property Alert Service

HMLR Property Alert Service

One of the simplest ways to protect yourself is to sign up for the HM Land Registry Property Alert Service, a free tool designed to notify you of suspicious or unexpected activity relating to your property.

What the Property Alert Service Does

Once registered, the service will monitor your property’s title and send you an email alert when important activity occurs, including:

  • Any attempt to register a mortgage or charge;
  • A change to the registered ownership or title details;
  • An Official Search (OS1 or OS2) being carried out by a conveyancer.

These alerts give you early warning of any unauthorised attempts to sell, mortgage or transfer your property.

How the Service Protects You

You simply enter the property address or title number when creating your account. If HM Land Registry detects potentially fraudulent activity — such as someone trying to change the owner’s name or secure a mortgage without your consent — you’ll receive an immediate notification. Acting quickly can stop the transaction before it completes. Create your account and read more here: HM Land Registry – Property Alert  

Why Official Search Alerts Are So Important

A key benefit of the service is the alert you receive when an Official Search is made. These searches are carried out just before completion of a property sale, purchase or remortgage. If you receive an Official Search alert and you were not expecting one, it may indicate that someone is attempting to fraudulently transact on your property. Prompt action can prevent the loss of your home or equity.

Choosing Which Properties to Monitor

The system allows you to monitor up to 10 properties, which is typically sufficient for most homeowners and landlords. Creating extra accounts is not permitted and could lead to suspension, so if you own more than 10 properties, prioritise the highest-risk titles. Consider:

  1. Property Value - Higher-value homes are more attractive targets for property fraudsters;
  2. Whether the Property Is Mortgage Free - Fraudsters can see if a property is mortgaged, but not the outstanding balance. Mortgage free properties appear to have more accessible equity, making them prime targets;
  3. Tenant Turnover Properties - with new tenants, short-term lets, HMOs or holiday lets may be at increased risk because criminals often need physical access for viewings or mortgage valuations;
  4. Empty or Unoccupied Properties - Vacant properties are much easier for fraudsters to enter, claim ownership of, or use to facilitate a fraudulent sale or remortgage.

Strengthen Your Property Security

The HM Land Registry Property Alert Service offers an effective, free layer of protection against property title fraud. For landlords, second-home owners, investors and anyone with an empty or mortgage-free property, registering is strongly recommended.

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