AML regulation is evolving and firms need to stay ahead

Julie James, Director, Corporate Audit

Recent updates to the UK’s anti-money laundering (AML) framework signal a shift in regulatory expectations. From proposed changes to the Money Laundering Regulations to new corporate offences, organisations across all sectors must ensure their compliance strategies are keeping pace.

This update outlines the key developments and what they mean for firms subject to AML obligations.

Government consultation proposes changes to AML rules

HM Treasury recently closed a consultation on proposed amendments to the Money Laundering Regulations (MLRs). The changes aim to improve clarity, close regulatory gaps and strengthen the UK’s AML regime. Key proposals include.

Enhanced customer due diligence requirements.
Clarifications on the use of pooled client accounts.
Updates to crypto asset regulation.
Changes to trust registration obligations.

These updates are expected to be implemented through a statutory instrument later this year. Organisations should begin reviewing their policies and procedures to ensure alignment with the proposed changes.

New corporate offence introduces liability for fraud

From 1 September 2025, large organisations are now subject to a new offence under the Economic Crime and Corporate Transparency Act. The ‘failure to prevent fraud’ offence creates liability where a business has not put in place reasonable procedures to prevent fraudulent conduct by employees or associates.

This development complements existing AML obligations and reinforces the need for:

documented fraud prevention frameworks
clear governance and accountability structures
regular training and monitoring.

Organisations that already have AML controls in place may need to expand their scope to include fraud specific risks and procedures.

AML risks continue to evolve across sectors

Regulators are increasingly focused on sector specific risks. These include the following.

Crypto assets
The FCA and other bodies are tightening expectations around due diligence and transaction monitoring for digital finance.
Real Estate
Global trends suggest increased scrutiny of all-cash property transactions and beneficial ownership transparency.
Professional Services
Firms offering legal, accounting or advisory services are expected to demonstrate robust AML controls, particularly in high-risk areas such as client onboarding and fund flows.

These trends reflect a broader shift towards proactive supervision and data-driven enforcement.

What firms should be doing now

To stay ahead of regulatory change, organisations should consider:

reviewing AML policies and procedures considering proposed updates
conducting a gap analysis against the new fraud offence requirements
ensuring governance structures support both AML and broader financial crime compliance
seeking independent assurance through an AML audit or health check.

Crowe’s AML team supports clients with tailored reviews, policy development and independent audits. We help firms understand their obligations and implement practical solutions that meet regulatory expectations.

Be proactive and prepare for change

AML regulation is not standing still. Firms that wait for final legislation or enforcement action may find themselves exposed to unnecessary risk.

If you’re reviewing your AML framework or preparing for upcoming changes, now is the time to act. A proactive approach can help you stay compliant, protect your reputation and demonstrate your commitment to financial crime prevention.

Crowe can help you with the above as part of their AML service, please contact Julie James for more information.