UK: HM Treasury publishes supervision report on Anti-Money Laundering and Counter-Terrorist Financing 2022 – 2023
May 21, 2024
UK: HM Treasury publishes supervision report on Anti-Money Laundering and Counter-Terrorist Financing 2022 – 2023May 21, 2024 On 1 May 2024, HM Treasury (’HMT’) published its annual report on the performance of Anti-Money Laundering (‘AML’) and Counter-Terrorist Financing (‘CTF’) supervisors. The report covers the period of 6 April 2022 – 5 April 2023 (the ‘Relevant Period’). Supervisory activitiesAML/CFT supervisors are required to adopt a risk based approach to their supervisory activities. This requires an in-depth understanding of the sector they are responsible for and the nature of the parties they supervise. This enables supervisors to focus activities on areas of higher risk of money laundering and terrorist financing.
Supervisory findingsThe report sets out common themes of non-compliance with the MLRs. In particular, the FCA reported that common themes it identified included:
The GC identified similar issues but also highlighted that it found evidence within its non-compliant population that (i) AML/CTF concerns were outweighed by commercial and/or reputational considerations (ii) policies and procedures were not adequately documented and (iii) there was an overreliance on monetary thresholds to drive compliance as opposed to a proper risk based approach to compliance being applied. Promoting complianceAcross all 25 supervisors during the Relevant Period total fines of £197 million were levied for non-compliance with the MLRs. This is a significant reduction from the £504 million of fines during 2021-22, however a large proportion of this was due to historic, sizeable fines issued by the FCA during the 2021-22 period. ConclusionThe report highlights a number of strengths of the supervisory approach in the UK with respect to AML/CTF, however, it is clear that there are further improvements which can be made. This has been recognised by HMT and there are on-going consultations relating to changes to the MLRs and the supervisory approach adopted in relation to AML/CTF. Latest InsightsLatest News
Latest Events
legal updates June 17, 2026 Commercially Connected Shorts - 17 June 2026 legal updates June 16, 2026 EU Pay Transparency Directive: Job evaluation and classification guideline... legal updates June 14, 2026 Global Sustainability & ESG Insights - May 2026 legal updates June 11, 2026 EU adopts renewed foreign investment framework client news June 17, 2026 Advising Trane Technologies on the acquisition of Transport-Kälte-Vertrieb ... firm news June 15, 2026 Eversheds Sutherland continues European expansion with further strategic pa... client news June 09, 2026 Eversheds Sutherland powers 12 key deals for Gresham House Energy Storage F... client news June 04, 2026 Next stop, public ownership: Eversheds Sutherland advises DfT on GTR transi... virtual Introduction to Swiss employment law June 23, 2026 2pm - 5pm (GMT) Virtual virtual Energy Transition Series - Project Financing BESS: Comparing the UK market ... July 08, 2026 10:00 ET | 15:00 BST | 16:00 CET virtual UAE - Employment law in the Dubai International Financial Centre September 10, 2026 9.30am - 1.30pm (GMT) Virtual in-person Basic foundations of US employment law September 17, 2026 9.30am - 4.30pm (GMT) London, United Kingdom |