Failure to Prevent Fraud – New Offence from September 2025
A new corporate criminal offence, `failure to prevent fraud’, came into force on 1 September 2025, introduced under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). This legislation is designed to drive a cultural shift in how large organisations approach fraud prevention, placing legal responsibility on them to take proactive steps to stop fraud committed by individuals acting on their behalf.
Find out more – New measures to tackle fraud come into effect – GOV.UK
New General Licence INT/2025/7323088 – October 2025 to April 2026
Since 31 October 2022, payments from persons designated under the Russia or Belarus sanctions regimes have been covered by OFSI general licences.
From 29 October 2025 to 28 April 2026, OFSI has issued General Licence INT/2025/7323088, which permits UK legal firms and counsel to receive payments from designated persons under the Russia and Belarus sanctions regimes.
The licence includes the following payment caps:
- Legal fees: Up to £2,000,000 per matter (including VAT)
- Expenses: Up to 10% of fees, capped at £200,000
- Where no fees are received: Expenses up to £50,000 per designated person, per law firm, for the duration of the licence
All payments made under this licence must be reported to OFSI within 14 days, using the appropriate reporting forms. Records must also be kept for 6 years.
OFSI Annual Review 2024–25 published
The Office of Financial Sanctions Implementation (OFSI) released its Annual Review for 2024-25 on 15 October 2025, highlighting significant progress in strengthening the UK’s financial sanctions regime.
Key highlights:
- Frozen Assets: Reported frozen assets under UK sanctions rose to £37 billion, up from £24.4 billion last year, with Russia-related measures remaining the top priority.
- Enforcement: OFSI imposed approximately £500,000 in monetary penalties for sanctions breaches, signalling a continued commitment to proportionate and robust enforcement.
- Licensing Improvements: Enhanced responsiveness and transparency in licensing services to support legitimate business activity while mitigating unintended consequences.
- International Cooperation: First Memorandum of Understanding signed with the US Treasury and ongoing engagement with EU partners to strengthen global sanctions implementation.
- Intelligence-Led Approach: Publication of sectoral threat assessments and advisories to help businesses manage sanctions risks effectively.
OFSI’s focus remains on improving compliance, capability, and enforcement to ensure the UK’s sanctions framework is world-leading and fit for future challenges.
Read the full report: OFSI Annual Review 2024–25.
CRL’s AML Supervision Report 2024–25: key findings and next steps
CILEx Regulation (CRL) has published its latest AML Supervision Report, summarising progress in tackling money laundering and setting out priorities for the year ahead.
What we found:
- The sector’s overall risk rating has moved from low to medium, mainly due to weaknesses in source of funds checks and AML training.
- 24 desk-based reviews were completed:
- 9 firms rated compliant
- 13 generally compliant
- 2 non-compliant(outside MLR scope)
- Common issues included:
- Over-reliance on generic AML policies
- Poorly documented Client/Matter Risk Assessments
- Gaps in Customer Due Diligence and Suspicious Activity Reporting
What’s changing and why it matters
- AML Statements will move to a fully digital format with improved risk scoring.
- CRL will carry out four on-site inspections and thematic reviews on sanctions and SAR compliance.
- Continued focus on training, governance, and collaboration with OPBAS and HM Treasury.
These steps aim to strengthen compliance, protect consumers, and maintain trust in the legal sector.
AML Supervision Report 2024–25
Sectoral Risk Assessment 2025
CRL’s annual Sectoral Risk Assessment report was published in September. The report identifies the key risks that could affect our regulated firms and supervised community. The assessment forms the basis of our Anti-Money Laundering (AML) compliance and supervisory work, by strengthening the resilience of our sector against financial crime.
The report helps provide a clear picture of the threats posed by money laundering, terrorist financing, and proliferation financing. This insight allows us to:
- Focus our supervision where it matters most, and
- Provide practical advice and guidance to help firms reduce risk.
We also keep a close eye on the wider regulated community to ensure that any activities falling under the Money Laundering Regulations (MLR) are identified and addressed.
The Sectoral Risk Assessment helps firms meet their own obligations under Regulation 18 of the MLR by highlighting risks and providing guidance on effective mitigation strategies when completing their Practice-Wide Risk Assessments.
Keep up-to-date with the latest Economic Crime and Financial Sanctions updates from CILEx Regulation.
