Action plan for anti-money laundering and counter-terrorist finance

The Home Office and HM Treasury have published an action plan for anti-money laundering and counter-terrorist finance. 

The National Risk Assessment (October 2015) highlighted weaknesses in the UK’s overall Anti-Money Laundering (AML)/Counter Financing of Terrorism (CFT) regime. One of the weaknesses identified was inconsistency in supervision. 

HM Treasury has committed to undertake a review of the UK’s AML/CFTSupervisory Regime and examine options for reform that will address those inconsistencies and build a more effective system. This review represents an important step towards ensuring that the UK’s regime is proportionate and meets the standards set by the Financial Action Task Force (FATF), ahead of the UK’s FATF Mutual Evaluation in 2017/2018.

As part of the action plan, the government is seeking views on potential changes to legislation and have also issued a Call for Information: Anti-Money Laundering Supervisory Regime. Both consultations close on 2 June.

The government states that the three priorities of the action plan are:

  1. create new legal powers and capabilities for law enforcement agencies
  2. reform the supervisory regime
  3. increase international reach by working with international groups such as the G20 and Financial Action Task Force (FATF).

The action plan contains a number of proposals on which the government wishes to consult, as they will involve potential changes to legislation. These are:

  1. removal of the Suspicious Activity Reports (SARs) consent regime
  2. new powers for law enforcement agencies to require reporters to take actions in relation to their customers, and to request further information on SARs
  3. data sharing between private sector organisations to tackle money laundering and terrorist financing
  4. the creation of a new power to require individuals to declare their sources of wealth
  5. the creation of a linked power to seek forfeiture of assets if they fail to declare their sources of wealth
  6. the creation of an illicit enrichment offence
  7. a power to designate an entity as being of money laundering concern
  8. development of a new power to allow money held in bank accounts to be swiftly seized and forfeited
  9. changes to the civil recovery powers to allow administrative seizure up to £100,000.


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