National risk assessment of money laundering and terrorist financing 2025
The 2025 National Risk Assessment (NRA) is the UK’s fourth comprehensive review of money laundering and terrorist financing risks. It outlines how these risks have evolved since the 2020 NRA and highlights the actions taken to address them. Firms should use the NRA to inform their own risk assessments, helping them understand both the UK’s overall threat landscape and the specific risks relevant to their business activities.
Headline Findings:
- The UK remains highly exposed to money laundering due to its global financial role, openness, and attractiveness to illicit finance.
- Global instability since 2020 has reshaped criminal methodologies, with increasing overlap between money laundering, kleptocracy and sanctions evasion, emphasising the need for robust Source of Funds checks.
- Cash-based laundering remains widespread, including smuggling via money mules and use of legitimate channels like Post Offices to place illicit funds into the financial system.
- Terrorist financing in the UK remains low in volume but continues to exploit both legal and illegal channels, posing ongoing risks to the regulated sector.
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Companies House updates
Identity Verification Requirement from 18 November 2025
From 18 November 2025, all company directors and persons with significant control (PSCs) must verify their identity under the Economic Crime and Corporate Transparency Act 2023. This measure, confirmed by Companies House, aims to enhance transparency and trust in UK businesses by ensuring those who set up, run, and control companies are identifiable.
Further Information: When you need to verify your identity for Companies House – GOV.UK
Help to Grow: Business Courses for SMEs
The Small Business Charter is offering two tailored courses to support SME growth. Help to Grow: Management Essentials is a fully funded online course for sole traders and start-ups, featuring bite-sized content to build strategic thinking and confidence. The Help to Grow: Management Course includes expert-led sessions, mentoring, and peer networking, providing practical tools to improve efficiency, expand into new markets, and scale operations.
Further Information: About the Help to Grow: Management Course | Small Business Charter & Help to Grow: Management Essentials | Small Business Charter
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HM Treasury Publishes MLRs Consultation Response
HM Treasury has published its response to the consultation on Improving the Effectiveness of the Money Laundering Regulations (MLRs), following over 200 submissions from stakeholders. The response outlines targeted reforms to close regulatory loopholes, clarify obligations, and ensure due diligence efforts are focused on higher-risk activity.
Key Proposals:
• Enhanced Due Diligence (EDD) for High-Risk Countries Refined: Enhanced Due Diligence to be mandatory for jurisdictions on the Financial Action Task Force (FATF) “Call for Action” list, reducing the burden for countries under “Increased Monitoring.”
• Currency Thresholds Aligned: All euro-denominated thresholds in the MLRs to be converted to GBP on a 1:1 basis, simplifying compliance and aligning with UK currency standards.
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Threshold Change under POCA Amendment Order 2025
The Proceeds of Crime (Money Laundering) (Threshold Amount) (Amendment) Order 2025 came into force on 31 July 2025, raising the s339A threshold from £1,000 to £3,000.
The new threshold sets the monetary limit below which businesses may act without committing a money laundering offence when exiting or operating an account under suspicion.
This change aims to reduce low-value DAMLs and enable greater focus on higher-risk activity across the AML regime.
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Sanctions Enforcement Update: £300,000 Penalty Issued for Breach of Russia Sanctions
On 31 July 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) fined Markom Management Limited £300,000 for breaching Russia-related financial sanctions by instructing a payment of £416,590.92 to a designated individual subject to asset freezes. OFSI found that MML acted with knowledge of the sanctions and lacked adequate compliance controls, emphasising that all firms must maintain robust sanctions frameworks and report breaches promptly. This enforcement supports the UK’s broader strategy to hold Russia accountable and includes a consultation on tougher penalties and faster case resolutions.
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Economic Crime Quarterly – Home Office updates
The latest edition of the Economic Crime Quarterly from the Home Office – April 2025 includes Fraud Prevention and Protection case studies, plus an update on the fraud strategy expansion (as part of the government’s Plan for Change).
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CILEX Journal – summer 2025
Recent AML feature from CRL, CILEX Journal – Avoiding anti-money laundering pitfalls
Keep up-to-date with the latest Economic Crime and Financial Sanctions updates from CRL.
