Journey
Meet anti-money laundering requirements
Essential guide to AML compliance for UK businesses in regulated sectors. Covers registration with supervisors, customer due diligence, suspicious activity reporting, appointing an MLRO, record keeping, staff training, and penalties for non-compliance.
Do you need to comply with AML regulations?
The Money Laundering Regulations 2017 (MLR 2017) require certain businesses - called 'obliged entities' - to implement anti-money laundering controls. If your business operates in a regulated sector, you must register with an AML supervisor before trading.
Not every business is in scope. The regulations apply by activity, not by industry label. A construction business, for example, is only MLR-supervised if it independently carries on a regulated activity - such as doing estate agency work, accepting cash payments of EUR 10,000 or more for goods as a high-value dealer, or providing accountancy services. Building or trade work itself is not a regulated activity, and accepting large cash payments for construction services does not make you a high-value dealer (the high-value dealer rules apply to goods). The same activity-based test applies to professional services firms such as architects, engineers and consultants - most are out of scope unless they do regulated work.
This journey guides you through establishing AML compliance, from registration to ongoing monitoring.
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Identify your AML supervisor
Your AML supervisor depends on your business sector. Register with the correct body before you start trading - operating without registration is a criminal offence.
AML compliance guide
Complete guide to Money Laundering Regulations 2017 requirements for obliged entities.
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Register for AML supervision
Registration must be completed before commencing relevant business activity. HMRC charges a one-off application fee of £300 plus a premises fee of £400 per premises per year (small businesses with turnover under £5,000 pay in full and can then claim a £500 refund); FCA fees vary by firm type. Professional body supervision typically involves a fee.
gov.uk
Register for money laundering supervision (opens in a new tab)
HMRC online registration for businesses supervised by HMRC.
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Appoint a Money Laundering Reporting Officer (MLRO)
You must appoint an MLRO where appropriate to the size and nature of your business - a senior person responsible for receiving internal reports of suspicious activity and deciding whether to submit SARs to the National Crime Agency. The MLRO must have sufficient seniority and resources. Sole practitioners without relevant employees act as their own reporter.
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Implement customer due diligence (CDD)
Before establishing a business relationship, you must identify and verify your customers. The level of due diligence depends on the risk assessment - standard CDD for most customers, enhanced due diligence for higher-risk situations.
Enhanced due diligence (EDD)
Higher-risk customers require enhanced due diligence - additional verification, senior management approval, and ongoing monitoring. EDD is mandatory for certain categories.
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Complete your business-wide risk assessment
You must document the money laundering and terrorist financing risks specific to your business. This assessment forms the foundation for your policies and procedures, and must be reviewed annually.
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Create AML policies and procedures
Written policies and procedures must cover all aspects of your AML compliance - customer due diligence, risk assessment, suspicious activity reporting, and record keeping. These must be approved by senior management.
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Report suspicious activity
If you know, suspect, or have reasonable grounds to suspect money laundering or terrorist financing, you must submit a Suspicious Activity Report (SAR) to the National Crime Agency. Failure to report is a criminal offence punishable by up to 5 years imprisonment.
Critical: Do not 'tip off' the customer that you have filed a SAR - this is also a criminal offence.
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Provide staff training
All staff must receive AML training appropriate to their role. This includes recognising suspicious activity, understanding CDD requirements, and knowing how to report concerns internally to the MLRO.
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Keep adequate records
All AML records must be retained for at least 5 years after the business relationship ends or the occasional transaction is completed. Records must be made available to your supervisor on request.
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Understand penalties for non-compliance
Non-compliance with AML regulations carries severe consequences including criminal prosecution, unlimited fines, and prohibition from conducting business. Directors and senior managers can face personal liability.
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Maintain ongoing compliance
AML compliance is not a one-time exercise. You must continuously monitor business relationships, update risk assessments, refresh training, and respond to regulatory changes.
Further resources
Use these official sources to stay up to date with AML requirements and high-risk country lists.
legislation.gov.uk
Money Laundering Regulations 2017 (opens in a new tab)
Full text of the regulations on legislation.gov.uk.
jmlsg.org.uk
JMLSG Guidance (opens in a new tab)
Industry guidance from the Joint Money Laundering Steering Group for financial services.
gov.uk
High-risk third countries (opens in a new tab)
Current list of high-risk countries requiring enhanced due diligence.
gov.uk
UK National Risk Assessment (opens in a new tab)
HM Treasury's assessment of money laundering and terrorist financing risks to the UK (2025 edition).