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 Insights
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