On 7 December 2018, the Financial Action Task Force (FATF) published the results of its assessment of the UK’s anti-money laundering and counter terrorist financing (AML/CTF) regime. The assessment was a comprehensive review of the effectiveness of the UK’s measures and their level of compliance with the FATF Recommendations.
Key findings from the FATF’s assessment are:
- the UK has a robust understanding of its money laundering (ML) and terrorist financing (TF) risks which is reflected in its public national risk assessments (NRAs). National AML/CTF policies, strategies and activities seek to address the risks identified in the NRAs;
- the UK proactively investigates, prosecutes and convicts a range of TF activity, in line with identified risks. A particularly positive feature of the system is the strong public / private partnership on TF matters;
- the UK routinely and aggressively identifies, pursues and priorities ML investigations and prosecutions. It achieves around 7,900 investigations, 2,000 prosecutions and 1,400 convictions annually for standalone ML or where ML is the principal offence. The UK investigates and prosecutes a wide range of ML activity. Investigations of high-end ML have increased since being prioritised in 2014;
- all entities within the FATF definition of financial institutions and all designated non-financial businesses and professions (DNFBPs) are subject to comprehensive AML/CFT requirements and subject to supervision;
- the UK is a global leader in promoting corporate transparency and has a good understanding of the ML/TF risks posed by legal persons and arrangements;
- the UK’s overall AML/CTF regime is effective in many respects. It needs to address certain areas of weakness, such as supervision and the reporting and investigation of suspicious transactions. However, the country has demonstrated a robust level of understanding of its risks, a range of proactive measures and initiatives to counter the significant risks identified and plays a leading role in promoting global effective implementation of AML/CFT measures; and
- while suspicious activity reports (SARs) are high quality, the SAR regime itself requires a significant overhaul to improve the quality of financial intelligence available to the competent authorities.
The FATF has also published a consolidated table showing the latest evaluation of its members’ AML/CTF regimes.