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Consultation Response: Review of the UK’s AML/CTF Regulatory and Supervisory Regime

ACAMS response to Her Majesty’s Treasury’s call for evidence on the systemic effectiveness of the UK’s AML and CTF regulatory and supervisory regime, and how they contribute to tackling economic crime.

    Summary

    Effectiveness, proportionate approach, and supervisory powers are some of the themes assessed in the UK’s Financial Crime Regime review. Resulting from the 2019 – 2022 Economic Crime Plan, Her Majesty’s Treasury (HMT) has opened a consultation of the UK’s anti-money laundering (AML)/counter-terrorist financing (CTF) regulatory and supervisory regime and bodies. Following our panel discussion with industry executives, to address the themes raised by HMT on its systemic effectiveness, structure, and practical application of the Money Laundering Regulations (MLRs), ACAMS has submitted a response covering some of the thematic issues discussed.

    The AFC ecosystem must be agile and dynamic in its fight against illegal activity, and seize the opportunity presented under this review to determine how best to tackle this global issue. In support of this, ACAMS has identified some priority areas that should be considered as part of the broader review.

     

    Key Findings

    Effectiveness

    The need for defined and measurable outcomes of effectiveness

    Use of a risk-based approach

    Ensuring the right controls are driving the right outcomes

    Financial inclusion

    Supporting the dialogue that high risk is not bad risk

    Intelligence-led information sharing

    The use of public-private partnerships across all sectors

    Global divergence

    The real risk that the UK diverges from other global partners

    Structure of supervisory bodies

    Consistency of approach to create a degree of certainty and expectation for market participants

    Main Sectors

    • Financial Services
    • DNFBPs
    • Regulators
    • Law Enforcement