HMRC cracks down on AML failures. Are you next in line?
Date
September 29, 2025Author
Mukund Amin
Over the past few years, HMRC has made it clear that money laundering compliance is no longer something businesses can take lightly. The approach has toughened up as hefty fines, public naming and shaming, and closer checks are now very real risks for anyone falling short. If you are in a regulated sector, this is something you can’t afford to ignore.
Missing the mark on AML isn’t just an admin slip-up anymore. It is a financial and reputational risk that could cost your business thousands and seriously disrupt the way you operate. And with the cost of non-compliance rising, any business that is not completely following the rules could already be on HMRC’s radar.
So, what does this mean for your business? What are regulators actually expecting and how can you keep your business safe from penalties? Let’s break it down in this blog.
Why AML compliance is now under the spotlight
We all know that money laundering isn’t a new problem. But the way it happens has changed. With online payments, cryptocurrencies, shell companies, and cross-border trade, criminals now have more ways to hide money.
That’s why UK regulators like HMRC, the FCA, and the NCA are now keeping a much closer eye on businesses and raising the standards everyone has to meet.
At the centre of these efforts is the Money Laundering Regulations (MLRs), which apply to businesses in key sectors such as:
- Company formation agents
- Estate agents and letting agents
- High-value dealers (businesses taking cash transactions of at least 10,000 euros)
- Art market participants (AMPs) (trading or acting as an intermediary in the sale and purchase of works of art with a value of at least 10,000 euros)
- Trust or company service providers (TCSPs)
If your business is in one of these sectors, you must follow AML rules by law. If you don’t, it could lead to big fines, damage to your reputation, or even criminal charges.
The cost of getting it wrong
Breaking AML rules can be very costly for your money and your reputation. Even if you make a tiny mistake, it can lead to big problems and serious consequences. Here are a few examples of how your businesses can be affected:
Hefty financial penalties
Breaking AML rules can be very costly for your money and your reputation. Even if you make a tiny mistake, it can lead to big problems and serious consequences. Here are a few examples of how your businesses can be affected:
Business disruption
Non-compliant businesses can face temporary or permanent suspension from trading. HMRC also publishes the names of firms that have breached regulations, damaging your public image and customer trust.
Criminal investigations
Serious breaches can trigger investigations under the Proceeds of Crime Act (POCA). This can lead to criminal prosecution, director disqualification, and even imprisonment in extreme cases.
Loss of clients
Breaking the rules can hurt your reputation to a great extent. Clients and partners may not want to work with a business that does not follow the law. Trust is very important in a competitive market.
Are you at risk?
Many small and medium businesses break the rules by mistake. It usually happens not on purpose, but because they don’t fully understand what is required. Common pitfalls include:
- Using outdated AML policies
- Failing to register with HMRC under the MLR
- Not conducting regular risk assessments
- Missing client due diligence steps
- Lack of staff training
- No record-keeping of compliance activity
- Delays in submitting SARs
If any of these apply to your business, you must act now to stay on the safer side.
What you can do to stay compliant
Following HMRC rules doesn’t have to be scary. But you do need to act early. Here’s how to improve your AML compliance:
1. Register with HMRC (if required)
Make sure your business is registered with HMRC under the MLR. If you’re not sure if it applies to you, it is better to ask an accountant or compliance expert about it.
2. Review and update your AML policies
Review your internal procedures regularly. Make sure they align with the latest legal guidance and industry best practices. They should clearly define roles, responsibilities, and escalation procedures.
3. Perform comprehensive risk assessments
Perform a detailed risk analysis covering both your company’s activities and client relationships. Document it, review it annually, and make adjustments as necessary.
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4. Enhance client due diligence
You must verify the identity of your clients and understand the nature of their business activities. When dealing with overseas clients or those classified as politically exposed persons (PEPs), businesses are expected to perform Enhanced Due Diligence.
5. Train your team
All staff members should receive AML training relevant to their specific roles. Use external training providers or professional bodies that offer certified programs.
6. Maintain good records
Record-keeping is essential. You must be able to demonstrate to HMRC that your compliance efforts are genuine, ongoing, and properly documented.
7. Submit SARs when necessary
If you notice unusual or suspicious transactions, don’t ignore them. Follow the SAR reporting process through the NCA portal promptly.
Follow these steps, and your business can stay safe and sound. Be careful, stay prepared, and let compliance guide your way.
Final thoughts
Author
Mukund is a founding member of the Affinity Associates Group and has been with the practice for nearly 40 years. After completing his degree in Accounting and Finance, he went on to qualify with both ACCA and ICAEW in 1991. Over the years, he’s built deep expertise in consultancy, tax, business development, and corporate group structures. Mukund is known for helping clients make sense of complex financial challenges and turning them into opportunities for sustainable growth.