AML/CFT guide · United Kingdom
United Kingdom AML/CFT: A Reference Guide
An overview of the United Kingdom's anti-money-laundering and counter-terrorist-financing framework, the bodies that run it, its statutory history, and the core obligations on regulated firms.
Last updated 2026-06-20
The United Kingdom operates a multi-body anti-money-laundering and counter-terrorist-financing (AML/CFT) regime. Policy sits with HM Treasury; supervision is divided across a conduct regulator, statutory bodies, and professional-body supervisors; financial-intelligence and consent functions sit with the National Crime Agency; financial sanctions are implemented by OFSI; and corporate-transparency data is held by Companies House. This guide summarises the principal bodies, the legislative timeline, the current framework, and the core obligations on regulated firms, with citations to primary authorities.
Principal bodies and their roles
| Body | Role | Primary reference |
|---|---|---|
| HM Treasury (HMT) | Owns AML/CFT policy and makes the Money Laundering Regulations (secondary legislation); leads supervisory-reform decisions. | gov.uk/government/organisations/hm-treasury |
| Financial Conduct Authority (FCA) | AML/CFT supervisor for financial-services firms; registration and supervision body for cryptoasset businesses since 2020; hosts OPBAS. | fca.org.uk/firms/financial-crime |
| HMRC | Statutory AML supervisor for sectors not covered by the FCA, Gambling Commission, or professional-body supervisors (e.g. estate agents, money-service businesses, trust and company service providers, high-value dealers). | gov.uk/guidance/money-laundering-regulations-who-needs-to-register |
| Gambling Commission | Statutory AML supervisor for casinos. | gamblingcommission.gov.uk |
| Professional Body Supervisors (PBSs) | Supervise legal and accountancy firms; overseen by OPBAS, housed within the FCA since 2018. | fca.org.uk/about/how-we-operate/who-work-with/opbas |
| National Crime Agency (NCA) / UK Financial Intelligence Unit (UKFIU) | The UK FIU. Receives Suspicious Activity Reports (SARs) and operates the Defence Against Money Laundering (DAML) consent regime under POCA. | nationalcrimeagency.gov.uk |
| Office of Financial Sanctions Implementation (OFSI) | HMT body that implements and enforces financial sanctions; publishes asset-freeze data and imposes civil monetary penalties on a strict-liability basis. | gov.uk/government/organisations/office-of-financial-sanctions-implementation |
| Foreign, Commonwealth & Development Office (FCDO) | Sets and designates UK sanctions policy under SAMLA; owns the UK Sanctions List. | gov.uk/government/organisations/foreign-commonwealth-development-office |
| Companies House | Maintains the company register, the People with Significant Control (PSC) register, and (since 2022) the Register of Overseas Entities; gaining gatekeeper and verification powers under ECCTA 2023. | gov.uk/government/organisations/companies-house |
Legislative history
| Year | Law / event | What it changed |
|---|---|---|
| 2000 | Terrorism Act 2000 (TACT) — c.11 | Part III creates terrorist-property and terrorist-financing offences and reporting duties; the CFT spine that runs parallel to POCA. legislation.gov.uk/ukpga/2000/11/part/III |
| 2002 | Proceeds of Crime Act 2002 (POCA) — c.29 | Core AML statute: principal money-laundering offences (ss.327–329), failure-to-disclose (regulated sector), tipping-off; the SAR / authorised-disclosure ("consent") regime (ss.335, 338); confiscation and civil recovery. legislation.gov.uk/ukpga/2002/29 |
| 2017 | Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017, SI 2017/692) | Transposed the EU 4th Anti-Money-Laundering Directive and the funds-transfer regulation; in force 26 June 2017. Introduced risk-based CDD/EDD, PEP screening, business-wide risk assessments, and beneficial-ownership obligations. Replaced the 2007 Regulations. legislation.gov.uk/uksi/2017/692 |
| 2018 | Sanctions and Anti-Money Laundering Act 2018 (SAMLA) — c.13 | Post-Brexit primary power to make autonomous UK sanctions and to continue making money-laundering regulations after EU exit. Operational from 31 December 2020. legislation.gov.uk/ukpga/2018/13 |
| 2019 → in force 10 Jan 2020 | Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (SI 2019/1511) | Transposed the EU 5th Anti-Money-Laundering Directive: brought cryptoasset exchange providers and custodian wallet providers into scope (FCA-registered), tightened EDD/PEP rules, and expanded scope to art dealers and lettings agents. legislation.gov.uk/uksi/2019/1511 |
| 2022 | Economic Crime (Transparency and Enforcement) Act 2022 (ECTEA) — c.10 | Fast-tracked after Russia's invasion of Ukraine; Royal Assent 15 March 2022. Created the Register of Overseas Entities at Companies House (live 1 August 2022; existing-holders deadline 31 January 2023); reformed Unexplained Wealth Orders; streamlined OFSI strict-liability penalties. legislation.gov.uk/ukpga/2022/10 |
| 2023 | Economic Crime and Corporate Transparency Act 2023 (ECCTA) — c.56 | Royal Assent 26 October 2023. Companies House reform (gatekeeper powers and mandatory identity verification); new corporate "failure to prevent fraud" offence; reform of corporate criminal attribution (the "senior manager" test); and crypto and civil-recovery powers. Commencement is phased. legislation.gov.uk/ukpga/2023/56 |
Current framework and core obligations
Customer due diligence (CDD) and enhanced due diligence (EDD). MLR 2017 (as amended) requires regulated firms to identify and verify customers and beneficial owners, understand the purpose and nature of the relationship, and apply EDD to higher-risk situations — including politically exposed persons (PEPs), high-risk third countries, and complex or unusual transactions. CDD must be risk-based and ongoing. legislation.gov.uk/uksi/2017/692
Risk-based approach. Firms must maintain a documented business-wide risk assessment, policies, controls and procedures and, where size warrants, a nominated officer (MLRO) and independent audit (MLR 2017, Parts 2–3).
SARs and the DAML consent regime. Under POCA, the principal money-laundering offences are ss.327–329. A person can obtain a defence by making an authorised disclosure (a SAR) to the NCA and obtaining appropriate consent (ss.335, 338) — known as a Defence Against Money Laundering (DAML). Statutory timing comprises a 7-working-day notice period and, if consent is refused, a 31-calendar-day moratorium; absent a refusal within the notice period, consent is deemed. An equivalent terrorist-property defence (DATF) applies under TACT. legislation.gov.uk/ukpga/2002/29/part/7; NCA UKFIU DAML/DATF guidance
Beneficial ownership and the PSC register. UK companies must identify and file People with Significant Control (over 25% of shares or voting rights, or significant influence or control) at Companies House — a public register. Overseas entities owning UK land must disclose registrable beneficial owners via the Register of Overseas Entities (ECTEA 2022). gov.uk/guidance/people-with-significant-control-psc
Financial sanctions. Since 31 December 2020 the UK has operated its own sanctions regime under SAMLA 2018, independent of the EU: the FCDO designates and OFSI implements financial sanctions. Breaching UK financial sanctions is a strict-liability matter — OFSI can impose civil monetary penalties without proving knowledge — and firms in scope have mandatory reporting duties to OFSI when they identify designated persons or frozen assets. legislation.gov.uk/ukpga/2018/13; OFSI
Penalties. POCA money-laundering offences carry up to 14 years' imprisonment. MLR 2017 breaches expose firms to FCA and HMRC civil penalties and, in serious cases, criminal liability (POCA ss.327–334). legislation.gov.uk/ukpga/2002/29
Recent developments
| Date | Development | Notes |
|---|---|---|
| 1 Sep 2025 | ECCTA "failure to prevent fraud" offence comes into force. | A corporate offence for large organisations (turnover over £36m, balance sheet over £18m, or more than 250 employees) where an associated person commits fraud for the organisation's benefit; a defence is available where reasonable prevention procedures were in place. |
| 8 Apr 2025 | Companies House identity verification (IDV) regime launches on a voluntary basis. | Part of ECCTA implementation, including the authorised corporate service provider (ACSP) framework. |
| 18 Nov 2025 | IDV becomes mandatory for new director appointments and new PSC registrations. | Reported to be phased for in-post directors and existing PSCs over the months that follow. |
According to HM Treasury, the UK is moving toward a single professional-services AML supervisor for the legal and accountancy sectors, with the FCA identified as the intended body; HMT consulted on the proposal in late 2025. The FCDO and HMT have also announced plans to consolidate UK sanctions designations into a single UK Sanctions List, after which the separate OFSI Consolidated List would cease to be updated; firms should confirm timing and scope against the FCDO and OFSI primary notices.
Sources and primary authorities
Primary legislation and official bodies (access date 2026-06-20):
- Terrorism Act 2000, Part III — https://www.legislation.gov.uk/ukpga/2000/11/part/III
- Proceeds of Crime Act 2002 (c.29), including Part 7 — https://www.legislation.gov.uk/ukpga/2002/29 ; https://www.legislation.gov.uk/ukpga/2002/29/part/7
- Money Laundering... Regulations 2017 (SI 2017/692) — https://www.legislation.gov.uk/uksi/2017/692
- Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (SI 2019/1511) — https://www.legislation.gov.uk/uksi/2019/1511
- Sanctions and Anti-Money Laundering Act 2018 (c.13) — https://www.legislation.gov.uk/ukpga/2018/13
- Economic Crime (Transparency and Enforcement) Act 2022 (c.10) — https://www.legislation.gov.uk/ukpga/2022/10
- Economic Crime and Corporate Transparency Act 2023 (c.56) — https://www.legislation.gov.uk/ukpga/2023/56
- FCA financial crime — https://www.fca.org.uk/firms/financial-crime ; OPBAS — https://www.fca.org.uk/about/how-we-operate/who-work-with/opbas
- OFSI — https://www.gov.uk/government/organisations/office-of-financial-sanctions-implementation
- NCA / UKFIU money laundering — https://www.nationalcrimeagency.gov.uk/what-we-do/crimes/money-laundering-and-illicit-finance ; DAML/DATF guidance — https://www.nationalcrimeagency.gov.uk/who-we-are/publications/776-ukfiu-chapter-3-understanding-damls-and-datfs/file
- Companies House — https://www.gov.uk/government/organisations/companies-house ; PSC guidance — https://www.gov.uk/guidance/people-with-significant-control-psc
- HMRC money-laundering registration — https://www.gov.uk/guidance/money-laundering-regulations-who-needs-to-register
This guide is general information, not legal advice, and is current as of 2026-06-20.
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