AML Laws in the UK

The United Kingdom's anti-money-laundering regime rests on two pillars: the Proceeds of Crime Act, which creates the principal money-laundering offences and the suspicious activity reporting duty, and the Money Laundering Regulations, which set out the preventative obligations firms must build into their controls.

Offences and reporting

The principal offences cover concealing, arranging and acquiring criminal property, and are drawn broadly. Regulated firms carry additional duties to report knowledge or suspicion, and failing to disclose is itself an offence in the regulated sector. Reports go to the National Crime Agency, which also administers the consent regime governing whether a firm may proceed with a transaction it has reported.

A fragmented supervisory landscape

Supervision is divided between the Financial Conduct Authority, HM Revenue and Customs, the Gambling Commission and a substantial number of professional body supervisors covering legal and accountancy services. OPBAS oversees the professional body supervisors. This fragmentation has been the subject of sustained review, with consolidation of supervision a recurring policy proposal.

Tools beyond prosecution

• Unexplained wealth orders, which reverse the evidential burden as to the source of an asset
• Account freezing and forfeiture orders, used widely and to civil rather than criminal standards
• The Companies House reform programme, tightening identity verification for company officers
• The register of overseas entities holding UK property

What this means in practice

Firms should expect supervisors to focus less on whether policies exist and more on whether they work: whether alerts are investigated properly, whether customer risk ratings reflect reality, and whether senior management can evidence oversight. Professional services firms in particular have moved from light-touch supervision to genuine enforcement exposure.