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ICAEW AML supervision report 2025/26: results and findings

Our AML Supervision Report 2025/26: Supervisory impact, sets out the results of our anti-money laundering (AML) monitoring and enforcement activity and the support we provide to help firms comply with the Money Laundering Regulations.

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What were the results of ICAEW'S AML monitoring in 2025/26?

ICAEW completed 1,608 monitoring reviews in 2025/26, compared with 1,185 in 2024/25.

  • 14.8% were compliant
  • 69.7% were generally compliant
  • 15.5% were non-compliant
  • 84.5% were therefore compliant or generally compliant, up from 80.0% in 2024/25.

The effort firms are putting into AML activity is paying off, but firms must not become complacent: continued investment in training, risk awareness and effective procedures remains essential.

Michelle Giddings, Head of AML, Regulation & Conduct

What were ICAEW's most common monitoring findings?

We saw significant improvements year-on-year in client identification, client risk assessments, verification procedures and persons with significant control reporting.

However, customer due diligence (CDD) issues continued to be the most common area of findings in 2025/26.

Biggest areas of non-compliance:

  • 7.8 of firms had ineffective ongoing CDD
  • 5.7% of firms had ineffective client identification
  • 5.5% of firms carried out ineffective client risk assessments
  • 5.2% of firms carried out ineffective firm-wide risk assessments

What is changing for AML supervision in 2026/27?

The AML supervisory landscape is changing. The government announced in October 2025 that the Financial Conduct Authority (FCA) will become the AML supervisory body for the accountancy, legal, and trust and company services sectors. ICAEW is working with the FCA and will continue to focus on maintaining effective supervision and supporting firms during the transition.

Firms must continue to comply with the current Money Laundering Regulations, regardless of their supervisory body.

Resources to support compliance

ICAEW publishes a wide range of resources to help firms comply with AML regulations:

Subscribe to Regulation & Conduct News to stay up to date on latest regulatory news or follow us on our dedicated Regulation & Conduct LinkedIn channel.

Our role

ICAEW supervises approximately 10,000 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 Regulation & Conduct Board (IRCB), ensuring independence and transparency in all decisions.

Reporting breaches

ICAEW provides a confidential and anonymous channel for reporting money laundering concerns.

Anti-money laundering supervision report 2025/26 front cover
Explore the report

Read the 2025/26 AML supervision report to find out the results of our quality assurance monitoring activity.

Read nowRegister for our webinar on key findings

Our expert

Headshot of Michelle Giddings
Michelle Giddings Head of AML

Michelle Giddings is ICAEW’s Head of AML with operational responsibility for the AML supervision of ICAEW’s 10,000 AML-supervised firms. She is co-Chair of the Accountancy AML Supervisors Group and was Chair of the AML Supervisors’ Forum in 2021. Michelle qualified as a Chartered Accountant in 2005, completing her training contract at a Big Four firm and working within audit for Professional Services firms. In 2009, Michelle joined ICAEW’s Quality Assurance Department as a Senior Manager, leading monitoring reviews to larger, higher-risk firms and managing a team of reviewers conducting monitoring reviews across the country.