United Kingdom: Money Laundering

Firms conducting certain activities which do not require full authorisation by the Financial Conduct (FCA) may still need to be registered with the FCA for the purposes of anti-money laundering (AML) supervisio

This weekly update examines recent UK sanctions enforcement actions, including a major alert on the A7 sanctions evasion network, OFSI's penalty against Citibank for Russia sanctions breaches, and the NCA's settlement with an agricultural trading company linked to suspected money laundering. The update also covers new strategic export control statistics and OTSI's annual review revealing 178 reports of potential trade sanctions breaches.

Unexplained Wealth Orders are powerful investigative tools that require individuals to prove the legitimate origins of their assets when they appear disproportionate to known lawful income.

The government has confirmed that anti-money laundering (AML) and counter-terrorist financing (CTF) supervision of law firms and accountancy practices will transfer from their existing professional body supervisors...

The UK art market faces heightened regulatory scrutiny as enforcement activity intensifies despite a downgraded money laundering risk rating. New amendments to Money Laundering Regulations and expanded sanctions reporting obligations signal a shift toward more active supervision, while recent prosecutions and significant fines demonstrate authorities' commitment to robust compliance frameworks across galleries, dealers, and auction houses.

The UK's Office of Financial Sanctions Implementation has imposed a £1 million penalty on Sabre Global Technologies Limited for continuing to provide services to a designated Russian airline after sanctions were imposed.

HM Treasury's Office of Financial Sanctions Implementation has introduced a comprehensive overhaul of its enforcement framework, featuring a revised case assessment matrix, new settlement and early account schemes...

The UK Information Commissioner has published guidance on a new lawful basis for processing personal data under the Data (Use and Access) Act 2025. This recognised legitimate interest basis allows controllers to rely on five pre-approved conditions without conducting traditional balancing tests, fundamentally shifting how organisations can justify data processing activities while maintaining compliance obligations.

In late 2025, HM Treasury set out its proposal to implement the government's decision for the Financial Conduct Authority (the "FCA") to become the sole anti-money laundering and counter-terrorist financing...