Introduction

The four pillars of UK AML law

The United Kingdom's anti-money laundering framework rests on four primary legislative pillars, each serving a distinct but interlocking function. Together, they create one of the most comprehensive AML regimes in the world, and, since 2025, one of the most actively enforced.

£186M+
FCA fines issued 2024/25 [1]
17/23
2024/25 FCA enforcement operations, 'financial crime' category [14]
37
Final Notices issued by FCA 2024/25 [1]
14 yrs
Maximum prison sentence for ML
🆕
2025-2026 updates
This guide incorporates the FCA's July 2025 PEP guidance (FG25/3), HM Treasury's July 2025 MLR reform response, the Failure to Prevent Fraud offence (in force from 1 September 2025), the FCA Financial Crime Guide amendments (PS24/17, published and effective 29 November 2024), and the Government's 21 October 2025 decision to make the FCA the future Single Professional Services Supervisor, subject to legislation and transition.

The four pillars are:

  1. Money Laundering Regulations 2017 (MLR 2017): the primary rulebook for AML compliance obligations
  2. Proceeds of Crime Act 2002 (POCA): establishes criminal offences and the SAR regime
  3. Terrorism Act 2000: addresses terrorist financing obligations
  4. Sanctions and Anti-Money Laundering Act 2018 (SAMLA): the post-Brexit UK sanctions framework

Layered on top of these are the FCA's Financial Crime Guide (FCG), FCA rules in SYSC 3.2.6R (insurers, UK ISPVs, managing agents and the Society) and SYSC 6.1.1R, the Senior Managers and Certification Regime (SM&CR), and a growing body of FCA guidance including the July 2025 PEP guidance (FG25/3).

Fighting financial crime is one of the FCA's four priorities for 2025 to 2030. The FCA says it will go further to disrupt criminals and support firms as an effective line of defence.
Pillar 01

Money Laundering Regulations 2017

Primary Law

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

SI 2017/692 · In force 26 June 2017 · Multiple amendments to 2026, including SI 2026/621 (in force 30 June 2026)

The MLR 2017 came into force on 26 June 2017 and revoked and replaced the Money Laundering Regulations 2007, subject to transitional provisions. They implemented the EU Fourth Money Laundering Directive in part. Their principal business obligations apply to relevant persons within Regulation 8, subject to Regulation 15 and other applicable limitations.

Who is in scope?

The MLR 2017 applies to a wide range of "relevant persons" carrying on business in the UK:

SectorExamplesRisk Level
Credit institutionsBanks, building societiesHigh
Financial institutionsPayment firms, EMIs, insurers, investment firmsHigh
Auditors & accountantsAudit firms, tax advisers, accountantsMedium
Legal professionalsSolicitors, barristers (certain activities)Medium
Estate agentsResidential and commercial property agentsMedium
High-value dealersFirms or sole traders dealing in goods who make or receive cash payments totalling at least £10,000 in respect of a transaction, whether in one operation or several operations that appear linked (changed from €10,000 to £10,000 on 30 June 2026, S.I. 2026/621) [13]Medium
CasinosLand-based and online casinosHigh
Cryptoasset businessesExchanges, wallet providers (from Jan 2020)High

Core obligations under MLR 2017

The MLR 2017 imposes a number of core obligations on relevant persons. This guide groups six of the most practically significant into the following themes:

  • Firm-wide risk assessment: identify and assess your ML/TF risks
  • Policies, controls and procedures: implement proportionate controls
  • Customer due diligence (CDD): identify and verify customers and beneficial owners
  • Ongoing monitoring: keep CDD up to date and monitor transactions
  • Record keeping: keep the records specified by Regulation 40 for the applicable retention period. After that period, personal data must be deleted unless a Regulation 40(5) retention ground applies
  • Training: ensure relevant employees and qualifying agents are trained

Key amendments since 2017

June 2017
MLR 2017 in force
Revoked and replaced MLR 2007. Introduced risk-based approach, enhanced beneficial ownership requirements, domestic PEP obligations.
January 2020
Cryptoassets brought into scope
From 10 January 2020, the FCA became the MLR supervisor for cryptoasset exchange providers and custodian wallet providers. New providers had to register before carrying on business, while existing providers received a statutory transition period.
March 2022
Russia sanctions: emergency amendments
Emergency expansion of UK sanctions legislation following Russia's invasion of Ukraine, including amendments to the Russia sanctions regulations and reforms under the Economic Crime Act 2022. [17]
January 2024
Domestic PEP clarification
Domestic PEP amendments take effect. Domestic PEPs remain within Regulation 35, but the statutory starting point is lower risk than for foreign PEPs and, absent enhanced risk factors, less extensive EDD must be applied. [15]
November 2024
FCA Financial Crime Guide updated (PS24/17)
The FCA updated FCG guidance on sanctions, proliferation financing and transaction monitoring, with further references to cryptoassets, Consumer Duty and data security and updated case studies.
July 2025
HM Treasury MLR reform response
HM Treasury confirms MLR amendments: narrowing EDD to "unusually complex" transactions, FATF blacklist-only for high-risk third countries, cryptoasset alignment with FSMA.
30 June 2026
MLR statutory instrument in force
The Money Laundering and Terrorist Financing Amendment Regulations 2026 (S.I. 2026/621) took effect 30 June 2026, implementing the July 2025 reform decisions, including the high-value dealer cash threshold change to £10,000.
🛡️ MLR in action
See how MLR screening obligations work in practice
The FinCrimeRadar screening tool demonstrates sanctions and PEP checks required under MLR 2017 and separate sanctions law, alongside adverse media screening, a widely used risk-management practice that supports PEP and risk identification but isn't itself a standalone universal MLR requirement.
Try the tool →
Pillar 02

Proceeds of Crime Act 2002 (POCA)

Criminal Law

Proceeds of Crime Act 2002

Chapter 29 · In force 24 February 2003 · Amended by numerous instruments

The principal money laundering offences in Sections 327 to 329 are not confined to the regulated sector. Part 7 also contains provisions with narrower regulated sector conditions, including Sections 330, 331 and 333A.

The three principal money laundering offences (Part 7)

Section 327: Concealing
Concealing, disguising, converting, transferring or removing criminal property from the UK.
Max: 14 years / unlimited fine
Section 328: Arranging
Entering into or becoming concerned in an arrangement which facilitates acquisition, retention, use or control of criminal property.
Max: 14 years / unlimited fine
Section 329: Acquisition
Acquiring, using or possessing criminal property.
Max: 14 years / unlimited fine
⚠️
What is "criminal property"?
Criminal property is any property that constitutes, or represents (wholly or partly, directly or indirectly), a person's benefit from criminal conduct, and the alleged offender knows or suspects that it constitutes or represents such a benefit. This is a broad definition. It includes the proceeds of tax evasion, fraud, corruption, drug trafficking, and any other criminal conduct, not just traditional money laundering.

The SAR regime: Section 330

Section 330 POCA creates the legal obligation to submit Suspicious Activity Reports for persons in the regulated sector. The offence of "failure to disclose" is committed when all of the following statutory conditions are met:

  • They know or suspect, or have reasonable grounds to know or suspect, that another person is engaged in money laundering
  • The information or other matter on which that knowledge or suspicion is based came to them in the course of business in the regulated sector
  • They can identify the other person, or the whereabouts of the laundered property, or they believe (or it is reasonable to expect them to believe) that the information will or may assist in identifying that person or property
  • They do not make the required disclosure to a nominated officer or a person authorised for Part 7 purposes by the NCA Director General under Section 330(4), as soon as practicable after the information or other matter described in Section 330(3) comes to them.
🚨
Tipping off: Section 333A
It is a criminal offence under S333A POCA to make a disclosure likely to prejudice an investigation in two circumstances: under s333A(1)/(2), disclosing that a disclosure falling within Section 337 or 338 has been made, where that underlying disclosure was itself based on information that came to the original discloser in the course of business in the regulated sector, and where the information on which this further disclosure is based came to the discloser in the course of business in the regulated sector; or under s333A(3), disclosing that an investigation into allegations of a Part 7 offence is contemplated or being carried out. The offence is subject to the permitted disclosure provisions in Sections 333B to 333D. Penalty: up to 2 years' imprisonment or a fine, or both, on indictment; on summary conviction, up to 3 months' imprisonment, a level 5 fine, or both. This means firms must be extremely careful about how they handle customer requests for information once a SAR has been filed.

Defence Against Money Laundering (DAML)

A person who makes an authorised disclosure under Section 338 may obtain the defence provided by Sections 327(2)(a), 328(2)(a) or 329(2)(a) for a specified act that would otherwise constitute an offence under the corresponding subsection (1). Appropriate consent may be express, deemed where no refusal is given before the seven working day notice period expires (which begins on the first working day after the disclosure is made, Section 335(5)), or deemed where consent was refused but the further 31-day moratorium period has since expired without a restraint or other order extending it. A DAML is not clearance or permission to proceed generally.

Asset recovery powers

POCA also grants law enforcement extensive asset recovery powers including: confiscation orders (post-conviction), civil recovery orders (no criminal conviction required), and cash forfeiture, which an account freezing order (AFO) may precede as a freezing step under Section 303Z9 rather than a recovery mechanism in itself. Unexplained wealth orders (UWOs) are a separate investigative tool, not a recovery mechanism themselves, they compel a respondent to explain the origin of property, and were reformed by the Economic Crime (Transparency and Enforcement) Act 2022. The Economic Crime and Corporate Transparency Act 2023 separately expanded confiscation and civil recovery mechanisms in relation to cryptoassets.

🧠 Knowledge check
Under POCA Section 330, what is the maximum prison sentence for failure to disclose (failing to file a SAR when required)?
Pillar 03

Terrorism Act 2000

CTF Law

Terrorism Act 2000

Chapter 11 · Principally in force from 19 February 2001 [5] · Amended by Counter-Terrorism Act 2008 and others

The Terrorism Act 2000 (TA 2000) addresses counter-terrorism financing (CTF): the financial crime of funding terrorist activities. POCA addresses criminal property derived from criminal conduct. The Terrorism Act addresses terrorist property: money or other property likely to be used for the purposes of terrorism (including the resources of a proscribed organisation), the proceeds of the commission of acts of terrorism, and the proceeds of acts carried out for the purposes of terrorism.

Key CTF offences

Section 15: Fundraising
Inviting or receiving money or property while intending, or having reasonable cause to suspect, that it may be used for terrorism; or providing it while knowing, or having reasonable cause to suspect, that it will or may be so used. [6]
Max: 14 years / unlimited fine
Section 16: Use/possession
Using money or other property for terrorism, or possessing property intending it to be used.
Max: 14 years / unlimited fine
Section 17: Funding arrangements
Entering into or becoming concerned in a funding arrangement while knowing or having reasonable cause to suspect that property will or may be used for terrorism. [6]
Max: 14 years / unlimited fine
Section 18: Money laundering
Entering into or becoming concerned in an arrangement facilitating another person's retention or control of terrorist property. A defence is available where the person proves that they did not know and had no reasonable cause to suspect that the arrangement related to terrorist property. [6]
Max: 14 years / unlimited fine

The CTF disclosure obligation: Section 21A

Section 21A creates a failure to disclose offence where its statutory conditions are met. A person who obtains relevant information in the course of regulated sector business must disclose it as soon as practicable to a constable or nominated officer, subject to the section's exceptions. The offence is broadly analogous to POCA section 330, but the provisions are not identical. [7]

💡
AML vs CTF: a key difference
Money laundering involves "dirty money": the proceeds of crime being cleaned. Terrorist financing can involve entirely "clean money": legitimately earned funds being diverted to terrorism. This makes CTF screening harder: a terrorist financier may have no criminal record, no suspicious transaction history, and may appear entirely legitimate. Screening against terrorist designation lists is therefore even more critical for CTF than it is for AML.
🛡️ Screen for terrorism financing risk
UN and OFAC lists include terrorist designation data
FinCrimeRadar screens against UN Security Council sanctions (which include terrorist designations) and OFAC's SDGT list, key tools for CTF compliance.
Screen now →
Pillar 04

Sanctions and Anti-Money Laundering Act 2018 (SAMLA)

Sanctions Law

Sanctions and Anti-Money Laundering Act 2018

Chapter 13 · Royal Assent 23 May 2018 · Commenced in stages from 23 May 2018 [4] · UK's post-Brexit sanctions framework

SAMLA gives the UK government the power to impose, maintain, and lift sanctions regimes independently following Brexit, without reliance on EU mechanisms. Prior to SAMLA, the UK could only impose sanctions through EU law or UN Security Council resolutions. SAMLA created the autonomous UK sanctions regime administered by the Office of Financial Sanctions Implementation (OFSI) under HM Treasury.

The UK sanctions architecture

  • OFSI: implements and enforces UK financial sanctions and issues licences permitting otherwise-prohibited transactions
  • FCDO: Foreign, Commonwealth & Development Office: leads on sanctions policy and publishes the UK Sanctions List, the authoritative source for UK sanctions designations
  • HM Treasury: ministerial accountability for OFSI and financial sanctions
  • FCA: supervises the adequacy of sanctions systems and controls at firms within its remit, including through SYSC where applicable

Civil monetary penalties under SAMLA

The Policing and Crime Act 2017 (section 146) introduced civil monetary penalties (CMPs) for sanctions breaches, meaning OFSI can fine firms without requiring criminal prosecution. SAMLA, passed the following year, later amended the 2017 Act so that sanctions regulations made under SAMLA also fall within its scope. Where the breach or failure relates to particular funds or economic resources and their value can be estimated, the maximum is the greater of £1 million and 50 per cent of that estimated value. In any other case, the maximum is £1 million.

The Economic Crime (Transparency and Enforcement) Act 2022 removed the mental element for civil monetary penalties: OFSI no longer needs to show the firm knew, suspected, or had reasonable cause to suspect it was breaching sanctions (section 146(1A)); the underlying evidential standard for establishing a breach remains the balance of probabilities (section 146(1)).

⚠️
Russia sanctions: the biggest test of SAMLA
Following Russia's invasion of Ukraine in February 2022, the UK imposed some of the most extensive sanctions in its history, designating hundreds of Russian individuals, entities, and vessels. In FinCrimeRadar's assessment, the pace and complexity of these designations is likely to have placed significant strain on firms' sanctions screening systems.
🛡️ UK sanctions screening
Search the UK Sanctions List in real time
FinCrimeRadar includes UK sanctions data via OpenSanctions: try screening individuals or entities to see their UK sanctions status.
Screen for UK sanctions →
Regulatory Layer

The FCA's financial crime framework

Above the legislative framework sits the FCA's own regulatory architecture for financial crime. For FCA-regulated firms, this layer is where the rubber meets the road: it translates the law into specific supervisory expectations.

SYSC rules: the foundation

Two rules in the FCA's Senior Management Arrangements, Systems and Controls (SYSC) sourcebook are central:

  • SYSC 3.2.6R: applies to insurers, UK Insurance Special Purpose Vehicles (ISPVs), managing agents and the Society (per SYSC 1 Annex 1, subject to its stated exceptions and activity scope), requiring reasonable care to establish and maintain effective systems and controls for regulatory compliance and for countering the risk that the firm might be used to further financial crime
  • SYSC 6.1.1R: requires firms to which the rule applies to have adequate policies and procedures sufficient to ensure compliance with the regulatory system and to counter the risk that the firm might be used to further financial crime [8]

The Financial Crime Guide (FCG)

FCG is non binding general guidance that provides practical assistance and examples relevant to the FCA's supervisory expectations. Firms may satisfy their obligations in other ways. The FCG covers: [9]

FCG ChapterTopic
FCG 1Introduction
FCG 2Financial crime systems and controls
FCG 3Money laundering and terrorist financing
FCG 4Fraud
FCG 5Data security
FCG 6Bribery and corruption
FCG 7Sanctions, asset freezes and proliferation financing
FCG 8Insider dealing and market manipulation

SM&CR: personal accountability for MLROs

Where the SMCR requires a firm's MLRO to perform the money laundering reporting function, that function is SMF17 and requires FCA approval before the individual starts. The individual is subject to the applicable fitness and propriety assessment, Senior Manager Conduct Rules, and personal accountability where the statutory and regulatory conditions for enforcement are met. [10] This means:

  • Where SMF17 applies, FCA approval is required before the individual starts the function
  • The FCA considers fitness and propriety, including competence, capability, reputation and sufficient capacity for the role
  • An approved SMF17 holder is subject to the applicable Senior Manager Conduct Rules, including SC4
  • Personal enforcement may follow where the relevant statutory or regulatory tests are met
👤
The MLRO's multiple functions
FCG 3.2.2 confirms that one individual can hold several distinct functions, though this is not required. These may include the regulation 21(1)(a) compliance officer role, the regulation 21(3) nominated officer role and the FCA MLRO role under SYSC 6.3.9R. Once appointed as the regulation 21(3) nominated officer receiving section 330 disclosures, POCA section 331(4) separately requires that person to disclose to a person authorised for Part 7 purposes by the NCA Director General as soon as practicable when the statutory conditions are met. The combination of these roles creates significant personal legal exposure. The FCA expects MLROs to have sufficient seniority, resources, and independence to perform these functions effectively.
What's changing

2025-2026 regulatory changes: What you need to know now

🆕
FCA PEP Guidance FG25/3: July 2025
The FCA's updated PEP guidance confirms that UK PEPs are generally lower risk than foreign PEPs. Non-executive board members of UK government departments and junior or mid-ranking civil servants are not classified as PEPs; only the most senior military officers, at Permanent Secretary-equivalent rank (Vice Admiral, Lieutenant General, or Air Marshal), can be. Individual MLRO sign-off is no longer required for every PEP relationship, provided another suitably senior person approves it, though the MLRO retains oversight of the firm's overall PEP process. Under Regulation 35(9)(b) and FG25/3, firms must document their reasoning when continuing EDD measures for a former PEP beyond the 12-month minimum. [3]
🆕
HM Treasury MLR Reform: July 2025
EDD requirements narrowed to "unusually complex" transactions (not all complex transactions). For high-risk third countries, EDD now limited to FATF "Call for Action" (blacklist) countries only. The FSMA 2000 (Cryptoassets) Regulations 2026 (S.I. 2026/102) have been made and will exclude authorised cryptoasset firms and specified investment cryptoasset firms from separate MLR registration, replacing it with a notification obligation under new regulation 56B, but this is not yet in force; full commencement is 25 October 2027.
🆕
Failure to Prevent Fraud: September 2025
The Failure to Prevent Fraud (FTPF) offence (Economic Crime and Corporate Transparency Act 2023) came into force 1 September 2025. The offence is committed where an associated person commits a qualifying fraud offence intending to benefit the organisation; having reasonable prevention procedures in place, or it being reasonable in the circumstances to have none, is a statutory defence under section 199(4), not a freestanding duty. A relevant body is large if, in the financial year preceding the fraud offence, it exceeds at least two of £36 million turnover, £18 million balance sheet total and 250 employees. Parent undertakings use the group test in section 202.
🆕
FCA as Future Single Professional Services Supervisor
The Government decided on 21 October 2025 that the FCA should become the SPSS. The current professional services population is split across 23 supervisors. The Financial Services and Markets Bill contains enabling provisions, but no official operational start date has been confirmed.
🔍 See the PEP changes in practice
Under FG25/3, UK PEPs are generally lower risk: test the difference
Search for UK politicians, ministers or civil servants on FinCrimeRadar and see how they appear in PEP screening data.
Try PEP screening →
Consequences

Penalties for non-compliance

The consequences of AML compliance failures in the UK are severe, operating across three dimensions:

💰
Civil / regulatory
Unlimited
FCA fines with no cap. OFSI CMPs up to the greater of £1m or 50% of estimated breach value, £1m in any other case. Senior manager bans.
⚖️
Criminal
14 years
Maximum imprisonment for POCA / TA 2000 offences. Unlimited fines. Confiscation of assets.
📉
Reputational
Existential
FCA Final Notices are public. Loss of authorisation. De-risking by correspondent banks.

Recent FCA enforcement cases: the pattern

The rows below are composite, illustrative scenarios built from recurring FCA enforcement patterns, not named cases with an identifiable Final Notice, they teach the pattern, not a specific firm's history.

Firm typeFailureConsequence
Challenger bankInadequate transaction monitoring, weak CDDMulti-million pound fine, enhanced supervision
Payment institutionSanctions screening gaps, failure to file SARsLicence restriction, skilled person review (s166)
Traditional bankSystematic AML control failures over multiple years£100m+ fine, executive personal censure
Cryptoasset firmFailure to register under MLRsCessation of business, FCA public warning
🚨
The FCA's five-step penalty calculation
Under DEPP 6.5, the FCA applies a five step framework: disgorgement; a seriousness figure, often based on relevant revenue for firms and, in non market abuse cases against individuals, relevant income; adjustment for aggravating or mitigating factors; any upward adjustment needed for deterrence; and any applicable settlement discount. A discount of up to 30 per cent may be available for qualifying Stage 1 settlements and does not apply to disgorgement. For penalties under FSMA section 206, the statute specifies no fixed monetary maximum. [16]
FAQ

Frequently asked questions

What is the difference between MLR 2017 obligations and POCA offences? +
MLR 2017 establishes preventative obligations and its own civil and criminal enforcement regime, including regulation 86. POCA establishes principal money laundering offences, disclosure offences and asset recovery powers. Conduct can breach one regime without necessarily breaching the other, although both may apply.
Does MLR 2017 apply to my fintech / EMI? +
EMIs and payment institutions carrying on listed activities are generally within scope as financial institutions through regulations 8(2)(b) and 10(2)(a), read with regulation 10(4)(a) (which defines "listed activity" by reference to Schedule 2) and Schedule 2 paragraphs 4 and 15. Account information services are excluded from paragraph 4. Cryptoasset exchange providers and custodian wallet providers are separately brought into scope as relevant persons under regulation 8(2)(j) and (k), a category that became effective on 10 January 2020. FCA authorisation alone does not determine MLR scope.
What changed under the July 2025 PEP guidance? +
The FCA's FG25/3 (July 2025) clarifies that UK PEPs are generally lower risk than foreign PEPs. Specifically: non-executive board members of UK government departments are not PEPs; junior or mid-ranking civil servants are not PEPs, and only the most senior military officers (Permanent Secretary-equivalent rank: Vice Admiral, Lieutenant General, or Air Marshal) can be; individual MLRO sign-off is no longer required for every PEP relationship, provided another suitably senior person approves it, though the MLRO retains oversight of the firm's overall PEP process; and under Regulation 35(9)(b), firms must document their reasoning when continuing EDD measures for a former PEP beyond the 12-month minimum. This guidance addresses the industry concern that domestic PEPs (including MPs and civil servants) were being over-screened relative to their actual risk. [3]
What is a Section 166 review? +
A Section 166 review (under FSMA 2000 s166(3)) is a "skilled person review". Under s166(3), the FCA can either require the firm to commission a skilled person nominated or approved by the FCA to review and report on specific aspects of the firm's activities, or appoint the skilled person itself. [11] In financial crime, s166 reviews typically look at AML controls, transaction monitoring, CDD quality, and sanctions screening. They are expensive and disruptive, fee levels vary by scope and firm size and we don't have a named FCA or industry dataset to cite a typical range. A s166 review is a supervisory tool, not itself an enforcement action, though it can precede one; receiving a s166 is widely regarded in the industry as a signal that the FCA has material concerns about a firm's controls, an operational observation, not a stated FCA position.
What is the UKFIU and how does it relate to SARs? +
The UK Financial Intelligence Unit (UKFIU) is a unit within the National Crime Agency (NCA) that receives, processes, and disseminates Suspicious Activity Reports (SARs). All SARs submitted by regulated firms go to the UKFIU via the NCA's SAR Portal. The UKFIU analyses SARs for financial intelligence and shares relevant information with law enforcement. In 2023/24, 872,048 SARs were submitted to the UKFIU [12]. Banks and other financial institutions account for the largest share of that volume, though we don't have a precise published breakdown to cite a specific proportion. Quality over quantity is a message this guide endorses, not a quoted FCA slogan: a well-reasoned SAR with good financial intelligence is far more valuable than a defensive SAR filed to avoid prosecution.
Verification

Sources

Each numbered claim above is checked against the specific source below it. This guide is mid-retrofit onto the site's verification ledger (37 of 103 flagged candidate claims sourced so far); figures without a bracketed number are not yet independently verified, see BACKLOG.md for the open remainder.

  1. Financial Conduct Authority, FCA Operating Service Metrics 2024/25, Enforcement Data. fca.org.uk/data/fca-operating-service-metrics-2024-25/enforcement-data
  2. Proceeds of Crime Act 2002, Sections 330 and 334. legislation.gov.uk/ukpga/2002/29/section/330 and legislation.gov.uk/ukpga/2002/29/section/334 (section 334 carries the penalty provisions; section 330 defines the offence)
  3. Financial Conduct Authority, FG25/3: The treatment of politically exposed persons for anti-money laundering purposes, 7 July 2025 (revised 15 July 2025). fca.org.uk/publications/finalised-guidance/fg25-3-treatment-politically-exposed-persons
  4. Sanctions and Anti-Money Laundering Act 2018, Section 64, and The Sanctions and Anti-Money Laundering Act 2018 (Commencement No. 1) Regulations 2018. legislation.gov.uk/ukpga/2018/13/section/64 (Royal Assent 23 May 2018; substantive provisions commenced in stages thereafter)
  5. Terrorism Act 2000 (Commencement No. 3) Order 2001, Article 2. legislation.gov.uk/uksi/2001/421/article/2/made (Act principally in force from 19 February 2001)
  6. Terrorism Act 2000, Sections 15, 17, 18, and 22. legislation.gov.uk/ukpga/2000/11/section/15, section/17, section/18, section/22 (penalty)
  7. Terrorism Act 2000, Section 21A. legislation.gov.uk/ukpga/2000/11/section/21A
  8. FCA Handbook, SYSC 6.1.1R. handbook.fca.org.uk/handbook/SYSC/6/1.html
  9. FCA Handbook, Financial Crime Guide (FCG), current contents. handbook.fca.org.uk/handbook/FCG
  10. FCA Handbook, SUP 10C.6.2R, FIT 1 and FIT 2, COCON 2.2.4R. handbook.fca.org.uk/handbook/SUP/10C/6.html
  11. Financial Services and Markets Act 2000, Section 166(3), and FCA, Skilled person reviews. legislation.gov.uk/ukpga/2000/8/section/166
  12. National Crime Agency, SARs Annual Report 2024 (872,048 SARs, 2023/24). nationalcrimeagency.gov.uk/who-we-are/publications
  13. Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, Regulation 14, as amended by S.I. 2026/621, regulation 9 (in force 30 June 2026). legislation.gov.uk/uksi/2017/692/regulation/14
  14. Financial Conduct Authority, enforcement data 2024/25, Table 7. fca.org.uk/data/fca-operating-service-metrics-2024-25/enforcement-data (17 of 23 enforcement operations opened in 2024/25 were financial-crime-related)
  15. The Money Laundering and Terrorist Financing (Amendment) Regulations 2023. legislation.gov.uk/uksi/2023/1371/contents/made
  16. FCA Handbook, DEPP 6.5, 6.5A, and 6.7. handbook.fca.org.uk/handbook/DEPP/6/5.html
  17. GOV.UK, Financial sanctions: Russia (look up amendments to the Russia sanctions regulations), and GOV.UK, New measures to tackle corrupt elites and dirty money become law. gov.uk/guidance/look-up-amendments-to-the-russia-sanctions-regulations and gov.uk/government/news/new-measures-to-tackle-corrupt-elites-and-dirty-money-become-law
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