London Daily

Focus on the big picture.
Wednesday, Jul 22, 2026

What Does the Future Hold for the UK’s Money Laundering Regulations?

What Does the Future Hold for the UK’s Money Laundering Regulations?

The UK government is reviewing its Money Laundering Regulations, and it is not alone. Around the world AML regimes are evolving – how will the UK’s compare?

Since July 2019, the UK government and private sector partners have been on a mission to upgrade the UK’s response to economic crime. This mission has been guided by the Economic Crime Plan, which lists 52 actions for how the response to economic crime should be bolstered. As monitored by RUSI’s Economic Crime Plan tracker, progress has been steady, with 80% of the actions either completed or in progress. In July 2021, a further action was initiated – Action 33, which calls for a review of the UK’s Money Laundering Regulations (MLRs) and the Office of Public Body Anti-Money Laundering Supervision (OPBAS) Regulations.

The MLRs are one of two pieces of legislation forming the foundation of the UK’s anti-money laundering and countering the financing of terrorism (AML/CFT) regime (the other being the Proceeds of Crime Act 2002). They set out how the private sector should ‘detect and prevent money laundering and terrorist financing … while minimising the burden on legitimate customers and businesses’.

Historically, the content of the MLRs was informed by the EU and its Anti-Money Laundering Directives (AMLDs). Following Brexit, the UK has ceased transposing the AMLDs and now has an opportunity to forge its own pathway.

The UK review is not the only introspection currently underway. In July 2021, the EU issued its latest and most ambitious AML Package, which sets out considerable reforms to how the EU AML/CFT regime will operate. Reforms are also being undertaken in the US, with the unveiling of the Anti-Money Laundering Act 2020 in December, which will now be operational over several years as its rules are set.

With all these reforms in motion, it is useful to consider what the UK can learn from other jurisdictions and what repercussions any divergences might have.

Convergence and Divergence


At the centre of the UK’s review is a Call for Evidence on the UK’s AML/CFT Regulatory and Supervisory Regime. This gives us some insights into what the future UK AML/CFT regime could look like, and where it may converge with and diverge from the EU and US. There are three areas of particular note:

1. Approach to Risk


Perhaps the most crucial theme emanating from this document is how the UK will expect the private sector to identify and control financial crime risk. This is a longstanding challenge requiring a balance to be found between meeting the regulatory requirements (often referred to as taking a ‘tick-box’ approach) and genuinely identifying the criminal risks an entity is exposed to based on its activities and product offering (the so-called Risk-Based Approach, or RBA). The consultation states that the government will remain committed to the RBA and will use this opportunity to explore the persistent frustrations which wed more cautious entities to the tick-box approach. It will examine how well risk is understood, what barriers exist to understanding risk and what more the government and supervisors could do to facilitate greater clarity on risk. Borrowing from the US, it asks whether the UK should introduce National AML/CFT Strategic Priorities to focus the private sector on particular risk areas. Although potentially useful, if these are introduced, the UK should learn from the first US iteration of such priorities, which have been received with scepticism given that they encompass all major economic crimes.

The UK is also toying with the idea of introducing a definition of ‘compliance programme effectiveness’. This would make it easier for the private sector to understand its obligations and demonstrate that it is employing effective controls. This idea is likely to be welcomed by the private sector. Earlier this year, the Wolfsberg Group (a group of the world’s 14 largest banks) published a letter setting out how the private sector believes it should demonstrate effectiveness in lieu of an official position.

Across the Channel, the EU has opted for a more prescriptive approach in its latest reforms. A new EU Rulebook on AML/CFT will be introduced for the private sector, accompanied by technical standards for compliance, moving away from the flexibility afforded by a risk-based approach. This difference in approach is likely to cause difficulties for firms that operate in both the UK and EU markets, and different control measures may be required in each.

2. Supervision


AML supervision – a fundamental cornerstone of any AML regime – is another significant element of the consultation. The UK’s fragmented system of three statutory supervisors and 22 Professional Body Supervisors (PBSs) has been subject to extensive criticism, including in the 2018 FATF evaluation of the UK, and has more recently been referenced by international partners as an example of the shortcomings of a multiagency model.

Since 2018, some improvements have been made, including the introduction of the Office of Public Body Anti-Money Laundering Supervision (OPBAS) to oversee the PBSs. Now, the government is going further and using this opportunity to ask fundamental questions about the structure and scope of the UK AML supervisory regime, including what role OPBAS should play.

Radically rethinking AML supervision is also on the agenda in the EU. The EU plans to introduce a new pan-European financial supervisor, the Anti-Money Laundering Authority, which will directly oversee the implementation of AML/CFT measures by the bloc’s riskiest financial institutions and monitor the national supervisors responsible for all other financial institutions. Crucially, it will intervene when national financial supervisors are deemed to be failing and usurp supervisory responsibility where necessary. The aim of this approach is to achieve greater consistency across the bloc, leaving fewer loopholes for criminals to exploit.

Consistency is something sorely lacking in the UK approach, and introducing a similar body responsible for oversight of the whole AML supervision sector certainly has some intuitive merits. If the UK retains its current AML supervision structure, however, it may be able to learn lessons from the EU in adopting its new ‘layered’ approach to supervision, and it should perhaps extend OPBAS’s mandate to include other, underperforming areas of UK supervision such as HMRC (responsible for trust and company service providers, the real estate sector and art market participants).

3. Technology and Data


After years of awkward co-existence, the utility of technology and data in the fight against financial crime is now widely accepted. The Call for Evidence makes it clear that the government plans to remove barriers to adoption of new technologies such as digital IDs. This level of support is analogous to sentiments in the US, where lawmakers have for years signalled a strong commitment to the use of new technology and innovation in compliance.

The EU is an interesting outlier on this topic. Although it is very supportive of the use of digital IDs, there are factions within the EU that are more sceptical of the widescale processing of personal data for compliance. In May of this year, for example, the European Data Protection Board sent a letter to the European Commission listing several concerns related to the need to balance data privacy and AML obligations, a balance it feels is incorrectly weighted in the latter’s favour.

There is an opportunity for the UK to show global leadership on this issue, particularly by aligning the latest version of its digital ID and attributes trust framework with the FATF’s Digital ID guidance, which will ensure that digital ID solutions being developed satisfy international standards for financial crime compliance.

What the Future Holds


Over the next few years, we are going to see significant reforms of the major AML/CFT regimes. As the UK pushes its own vision forward, there will be elements of convergence with its closest partners and areas where it carves out its own agenda. As a new framework develops, the UK should learn from partners in the EU and US and co-opt the best elements from each for its new independent vision. Failure to do so will only serve to create points of divergence which criminals will ultimately exploit.

Newsletter

Related Articles

0:00
0:00
Close
Northern Ireland Secures Additional Infrastructure Funding From UK Treasury
Wales Approves Port Investment Plans to Support Green Energy Supply Chains
UK Financial Regulator Simplifies Stock Market Rules to Attract More Listings
UK Reports Decline in Small Boat Crossings Across the English Channel
UK Government Creates Emergency Support Fund for Financially Pressured Universities
Scottish Government Launches Economic Strategy Focused on Innovation and Renewable Industries
UK Expands Sustainable Farming Incentives to Support Environmental Measures
UK Government Introduces New Neighbourhood Policing Standards Across England and Wales
UK Competition Regulator Opens Review of Artificial Intelligence Foundation Models
UK Deepens Indo-Pacific Security Cooperation After Talks With Singapore and Japan
UK Announces Rail Modernisation Plan for Northern England With New Infrastructure Funding
UK Government Updates Housing Planning Rules to Accelerate Residential Construction
UK Approves Major North Sea Offshore Wind Project to Support Clean Power Goals
UK Health Service Begins Major Digital Upgrade to Cut Hospital Waiting Times
Bank of England Holds Interest Rates Steady as UK Inflation Pressures Remain Persistent
UK Universities and Industry Expand Space and Defense Research Partnerships
House of Lords Approves Social Housing Bill Amendments on Shared Ownership Rights
House of Lords Advances Civil Aviation Bill With New Passenger Protection Measures
UK Government Suspends Tariffs on Fertilizer and Food Imports to Reduce Costs
Russell Group Universities Support New UK Business Department Focused on Innovation
UK Parliament Opens Inquiry Into Transport Barriers Facing Young Jobseekers
Home Builders Federation Calls for Lower Costs as New UK Government Sets Housing Priorities
Andy Burnham Meets UK Devolved Leaders to Strengthen Regional Cooperation
Andy Burnham Holds First International Calls With Trump, Macron, and Zelenskyy
Andy Burnham Reshuffles Cabinet With John Healey Appointed Chancellor of the Exchequer
Andy Burnham Government Removes VAT From Electricity Bills to Cut Household Costs
Andy Burnham Becomes United Kingdom Prime Minister After Sir Keir Starmer Resigns
Miliband Sets Climate and International Law at Centre of UK Diplomacy
US Gasoline Returns to $4 as Renewed Iran Fighting Disrupts Oil Flows
Czech Central Bank Governor Rejects Early Euro Entry and Rate-Cut Pressure
Trump Orders 50% Tariffs on Selected Canadian Imports
Pentagon Discloses Nearly 100 US Troop Injuries During Renewed Iran Fighting
Trump Readies New Tariffs as Temporary Global Levy Nears Expiry
US Judge Pauses Paramount Skydance and Warner Bros Discovery Merger Over Antitrust Concerns
NHS England Faces Growing Retention Pressure Among Younger Midwives
UK Data Centre Expansion Faces Water and Grid Capacity Challenges
UK Defence Shares Rise After John Healey Appointment and Continued Spending Commitments
OECD Urges UK Government to Review Pension Triple Lock to Protect Public Finances
Bank of England Keeps Cautious Approach as Energy Costs Threaten Inflation Progress
County Councils Call for Wider Devolution and Long-Term Social Care Funding Reform
IMF Urges UK Government to Maintain Fiscal Discipline as Growth Forecast Slows
Russian Warship Holds Live-Fire Exercises Near UK Coast as Royal Navy Monitors Activity
Mitie Agrees Three Point One Billion Pound Takeover by OCS in Another Blow to London Listings
JPMorgan Chase Warns Bank Levies Could Hit UK Growth and Drive Capital Away
UK Unemployment Holds at Four Point Nine Percent as Labour Market Shows Resilience
UK Government Borrowing Falls Below Forecasts as Treasury Receives Early Fiscal Boost
John Healey Cuts VAT on Household Electricity Bills After Cancelling National Digital ID Scheme
Andy Burnham Forms New Labour Government With Ten-Year National Renewal Plan
EU Imposes Record €550 Million Digital Services Fine on AliExpress
UK Publishes Updated Consumption-Based Carbon Emissions Data
×