There've been some genuinely significant developments in financial crime this past month. So much so that we've struggled to fit everything into just one episode. But when three major publications drop that fundamentally reshape how we approach AML in the UK, it's worth taking the time to unpack them properly.
This month, we're diving deep into three key documents that are recalibrating the UK's entire AML/CTF regime: the National Risk Assessment, the new System Priorities framework, and HM Treasury's response to the Money Laundering Regulations consultation. Each one carries serious implications for how you'll be managing compliance going forward.
Story 1: The National Risk Assessment 2025
The National Risk Assessment of Money Laundering and Terrorist Financing 2025 provides an updated assessment of the current threat landscape. Building on previous assessments from 2015, 2017, and 2020, this latest review shows how the risks have evolved since the last assessment.
The key findings include: over £12 billion in criminal cash is generated annually in the UK, with an estimated £10 billion potentially laundered through property alone. These figures reflect changes in how criminal networks are operating and adapting to new technologies and opportunities.
Technology-Driven Changes in Risk Profile
Three sectors have seen their risk ratings increase, with technology being a common factor across all of them.
Fintech firms (Electronic Money Institutions and Payment Service Providers) have moved from medium to high risk. Total payments value increased from £921 billion in 2020 to £2.06 trillion in 2023, representing significant growth in the sector. The assessment notes that criminals are increasingly using these platforms, often due to their streamlined onboarding processes compared to traditional banking.
Cryptoasset service providers have also moved to high risk, with the NCA estimating $1.7-5.1 billion in illicit crypto transactions linked to the UK annually. The FCA's registration process saw 48 of 368 crypto firms meet the required standards, highlighting compliance challenges across the sector. Unregistered firms continue to present elevated risks.
Casinos have shifted from low to medium risk, influenced by increased remote gambling adoption and evolving money laundering methodologies within these platforms.
Story 2: System Priorities 2025
The launch of the NCA and FCA System Priorities marks a significant step forward in aligning public and private sector efforts to tackle financial crime. The publication meets a commitment in the UK's second Economic Crime Plan. It marks a significant step forward in aligning public and private sector efforts to tackle financial crime and terrorist financing threats.
Nine Equal-Weight Priorities That Actually Matter
The nine priorities aren't ranked, but they're all actionable:
- Professional Enablers & Sanctions Evasion - particularly targeting Russia-Ukraine sanctions evasion
- Politically Exposed Persons (PEPs) - focusing on overseas corrupt officials
- Cryptocurrency Resilience - creating a more robust crypto ecosystem
- Criminal Cash Laundering - that £12 billion annual problem
- International Money Laundering - targeting organised groups from Albania, China, Russia, and UAE
- International Fraud - combating the 70% of UK fraud that originates overseas
- Money Mule Networks - disrupting the exploitation of vulnerable individuals
- Telecoms & Platform Fraud - tackling fraud from telecommunications and online platforms
- Terrorist Financing - preventing attacks and ideology propagation
Practical Implementation Strategy
The framework explicitly mentions that firms will be able to dial down regulatory activity to reallocate resources for maximum impact. This ties directly to upcoming changes, such as the increase in Defence Against Money Laundering reporting thresholds.
For mid-sized institutions, this creates a genuine opportunity to:
- Justify resource allocation decisions to your board with government backing
- Focus transaction monitoring on the highest-impact areas
- Build partnerships with peers facing similar challenges
- Demonstrate regulatory alignment in your next examination
The key is treating this as a strategic framework, not just another compliance checklist. Your next risk assessment should explicitly map your highest exposures against these nine priorities.
Story 3: Money Laundering Regulations Reform
HM Treasury's consultation response on improving the MLRs introduces a range of practical changes aimed at improving the effectiveness of the regulations. After 224 consultation responses, the government has made several adjustments that reflect how compliance works in practice.
Enhanced Due Diligence Gets More Targeted
The biggest change is moving from requiring EDD on "complex transactions" to only "unusually complex" transactions. This is an essential distinction for sectors like corporate finance, property, and M&A, where complexity is the norm, not the exception.
Similarly, mandatory EDD for high-risk third countries will now only apply to FATF's "Call for Action" list (currently North Korea, Myanmar, and Iran), not the broader "Increased Monitoring" list of 24 countries. This gives you more flexibility to apply risk-based approaches.
Currency Conversion and Operational Relief
All euro thresholds will convert to sterling on a one-to-one basis - so €15,000 becomes £15,000. This removes the administrative burden of constant currency conversions for UK-focused firms.
The new bank insolvency carve-outs will allow faster customer onboarding when banks fail, preventing the systemic bottlenecks we've seen in previous failures.
Trust and Company Services Tightening
Enhanced due diligence for Trust and Company Service Providers now includes mandatory customer due diligence when selling pre-formed companies, closing a significant regulatory gap.
The Bigger Picture: A System-Wide Recalibration
These three publications don't exist in isolation - they represent a coordinated effort to modernise the UK's financial crime prevention framework. The NRA provides the threat assessment, the System Priorities give you the focus areas, and the MLR reforms provide the practical tools to implement a more effective approach.
For compliance professionals, this represents the most significant opportunity in years to build truly effective programmes.
The government has given you the evidence base, the priorities, and the regulatory flexibility. What you do with it will determine whether your institution stays ahead of the evolving threat landscape.
The key insight? Financial crime prevention isn't just about satisfying regulators anymore - it's about doing what's right, even when it's difficult. These frameworks give you the tools to do exactly that.
Stay vigilant and stay ahead. Join us next month for more insights from The FinCrime Connection, brought to you by Jade ThirdEye.
This blog is based on the August 2025 episode of The FinCrime Connection, hosted by Claire and Phil from Jade ThirdEye. Claire brings over 20 years of financial crime expertise from her experience in financial services, while Phil represents our commitment to helping customers navigate these complex regulatory landscapes.