Examining non-compliance: 2024/25 anti-money laundering supervision report

ICAEW supervises approximately 9,500 firms under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR17), making us the largest professional body supervisor in the UK. Our role is to act as an improvement regulator—helping members and firms maintain high professional standards.

Our regulatory and conduct roles are overseen by the ICAEW Regulatory Board (IRB), ensuring independence and transparency in all decisions.

Most common issues observed at our monitoring reviews were customer due diligence (CDD), including ineffective risk documentation covering policies, procedures and controls, along with training.

• 1,185 monitoring reviews completed in FY24/25 (up from 1,112 in FY23/24)
• 19.4% of firms were compliant
• 60.6% of firms were generally compliant
• 20.0% of firms were non-compliant

Key findings from our supervisory activity

• 11.9% of firms had ineffective client identification procedures
• 12.6% of firms had ineffective risk documentation
• 10.2% of firms had ineffective verification procedures
• 11.6% of firms were not updating CDD throughout the duration of client relationships

• Quality assurance monitoring
• Read more about the most common areas of compliance monitoring

In cases where our monitoring review identifies serious concerns over compliance, we will prepare a report to the Practice Assurance Committee setting out the key issue and our recommended course of action. 

• 41 fines issued, totalling £197,706
• 3 exclusions from ICAEW membership

Sanctions include exclusion, unlimited fines, public reprimands, and conditions such as follow-up reviews and training.

Root causes of non-compliance

Common root causes: lack of understanding of regulations, insufficient risk assessment, and over-reliance on long-standing client relationships.

• Firms with less than £300k of income are under-represented within the population of firms referred for formal and informal follow-up action.
• Larger firms (over £2m income) are over-represented among those referred for formal and informal follow-up.
• Repeat findings are more common in mid-tier firms, while smaller firms are more likely to be referred for first-time issues

It is important that firms carefully reflect on findings from our monitoring reviews and ensure that they take effective action to rectify the areas of non-compliance identified so that they don’t recur.

Our strategy is to provide robust anti-money laundering supervision through a risk-based regime. We focus our efforts on firms where the risk that they will be used to enable money laundering is highest. At the same time, we offer help and support to our firms where appropriate.

Since the introduction of anti-money laundering (AML) supervision in 2007, we have performed in excess of 22,000 monitoring reviews.

The aim of our supervisory approach is to ensure that ICAEW remains compliant with the relevant requirements under the Money Laundering Regulations 2017 and OPBAS Sourcebook for professional body anti-money laundering supervisors (OPBAS Sourcebook).

• Read about our AML supervisory approach

ICAEW publishes a wide range of resources to help firms comply with AML regulations, including webinars, videos, guidance, bulletins and thematic reviews.

• Visit our AML resources hub
• Access ICAEW's Guidance on Sanctions for information on our fixed penalty process
• Watch All Too Familiar to explore the need for professional scepticism in the fight against economic crime

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