Why AML Compliance Matters More Than Ever

November 5, 2025
Money laundering is not a remote threat. It underpins fraud, corruption, drugs trafficking, terrorist financing, and even modern slavery. Particular sectors are attractive to money launderers because of the respectability and access it provides.

 

The main AML regulations

The United Kingdom’s Anti-Money Laundering and Counter-Terrorist Financing (MLTF) regime is underpinned by three principal legislative instruments:

  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)

  • The Proceeds of Crime Act 2002 (POCA)

  • The Terrorism Act 2000 (TA 2000)

Together, these form the legislative foundation for the UK’s approach to preventing and detecting financial crime.
In addition, a number of designated supervisory authorities and professional bodies are responsible for overseeing compliance, issuing sector-specific guidance, and enforcing the implementation of AML and counter-terrorist financing obligations.

 

Enforcement is Escalating

Following years of concentrated regulatory oversight of banks and other financial institutions, the UK Government and HM Treasury have significantly expanded their focus. The professional services and wider business sectors are now key areas of attention in the national effort to combat financial crime. As a result, the regulatory environment has become increasingly complex and demanding.

In 2018, HM Treasury established the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) to strengthen oversight of the professional body supervisors (PBSs) responsible for monitoring AML compliance within sectors such as accountancy and law. OPBAS has emphasised the importance of effective, risk-based, and outcome-focused AML controls across all supervised firms.

Consequently, PBSs and supervisory bodies, including HMRC, have intensified their supervisory activities through both on-site inspections and desk-based AML audits.

Recent enforcement actions demonstrate that failure to comply with AML requirements can result in significant consequences — including substantial financial penalties and long-term reputational damage.

  • Several firms have already received five-figure fines for inadequate AML due diligence procedures.

  • HMRC now publishes, on a biannual basis, a public register of firms fined for AML breaches, detailing the nature of the contraventions and the associated penalties.

 

A New Chapter in AML Supervision

On 21 October 2025, HM Treasury (HMT) published its Consultation Response outlining the outcome of the 2023 review on reforming the UK’s Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) supervisory framework.

The Government confirmed its intention for the Financial Conduct Authority (FCA) to become the single AML/CTF supervisor for professional services in the United Kingdom. This reform is designed to enhance consistency, reduce fragmentation, and strengthen the overall effectiveness of the UK’s AML/CTF supervisory regime.

While the transition plan, enabling legislation, and funding arrangements remain in development, firms should begin preparing for a more unified and rigorous supervisory approach. The FCA is expected to:

  • Build sector-specific expertise, particularly in the legal and accountancy fields;

  • Develop new systems, templates, and reporting mechanisms; and

  • Implement a data-driven, risk-based supervision model with enhanced enforcement capability.

The introduction of a single supervisor represents a material shift in expectations for professional services firms. Under the FCA’s oversight, AML supervision is anticipated to be more structured, transparent, and assertive than under the existing professional body framework.

 

Sectors Within the Scope of the Regulations

The UK’s Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) regulations apply to a broad range of professional and commercial sectors, each carrying distinct compliance obligations and supervisory expectations.

Professional services include:

  • Accountants and tax advisers

  • Law firms and legal practitioners

  • Trust and company service providers

Business sectors include:

  • Estate and letting agents

  • Property developers

  • Art market participants, including dealers and auction houses

  • Antique dealers, jewellers, and dealers in precious metals and stones

  • High-value goods dealers, such as car, yacht, and boat brokers

  • Cryptoasset service providers

For firms operating within these regulated sectors, AML compliance is not a procedural formality but a statutory obligation and an integral component of sound risk management. A robust AML framework is essential to:

  • Protect the business from financial crime and regulatory sanctions;

  • Maintain client confidence and uphold professional integrity;

  • Preserve authorisation and licensing to operate; and

  • Avoid costly remediation, disciplinary action, and reputational damage.

 

Stay Protected and Future-Proof Your Business

Given the intensifying regulatory scrutiny and the forthcoming transition to FCA supervision, firms cannot afford to be complacent in their AML/CTF compliance. Establishing and maintaining a robust, risk-based AML framework is essential to safeguard against financial crime, regulatory sanctions, and reputational damage.

At Bonham & Brook, we provide specialist AML consultancy services to help firms remain compliant, mitigate risk, and ensure regulatory readiness. Our services are designed to support organisations at every stage of AML compliance — from initial framework implementation to ongoing oversight.

One-off AML Frameworks
We develop and implement comprehensive compliance structures tailored to the firm’s specific risk profile, including:

  • Firm-wide risk assessments

  • Customised AML policies and procedures

  • Client risk reviews (KYC/CDD/EDD)

  • Staff training programmes

These solutions ensure that firms are fully aligned with current regulatory expectations and inspection-ready from day one.

Ongoing Compliance Support Packages
We offer three levels of continuous support, designed to provide scalable oversight in line with the firm’s requirements:

  • Core Compliance: Quarterly file and transaction reviews, refresher training, and helpline support.

  • Enhanced Assurance: Monthly file reviews, in-depth training workshops, sanctions and Suspicious Activity Report (SAR) support, and annual compliance statements.

  • Outsourced MLRO Support: Full oversight as your appointed MLRO, including unlimited advisory support, regulator-readiness audits, and policy updates — a cost-effective alternative to interim or fixed-term appointments.

 

Whether implementing a one-off AML framework or securing ongoing expert oversight, Bonham & Brook ensures that your AML programme is robust, practical, and fully regulator-ready.

 

 

Jon Arulthas

MLRO – Head of AML Compliance

Book a Meeting with Jon here

 

 

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