What information is HM Treasury asking for?
The questionnaire seeks practical examples and data on:
- how firms implement UN and UK sanctions updates, including screening processes and false‑positive rates;
- PF‑related risk assessments, controls and procedures;
- case studies showing how firms identify and respond to PF or PF‑related sanctions evasion risks;
- PF risk factors, typologies and sector vulnerabilities; and
- awareness of the latest national risk assessments and how these inform firmwide risk management.
Background: The FATF Mutual Evaluation
The United Kingdom’s next FATF Mutual Evaluation will commence in late 2026. This assessment will evaluate the UK’s compliance with the FATF’s 40 recommendations and the UK’s effectiveness in achieving the required Immediate Outcomes (IOs). HM Treasury is coordinating the UK’s preparation for this evaluation. Two of the outcomes, IO10 and IO11, specifically measure the UK’s ability to implement UN-mandated targeted financial sanctions, related to terrorist financing and proliferation financing respectively. The first part of this survey will ask IO10 and IO11 related questions and help inform the UK’s submissions to the FATF.
Background: UK Proliferation Financing National Risk Assessment
HM Treasury is currently updating the UK’s PF NRA to identify PF risks and typologies across sectors and strengthen the UK’s response. Your input to the second part of this survey will help ensure the PF NRA reflects real-world risks and challenges faced by firms.
Why your input matters
ICAEW‑regulated firms play a vital role in the UK’s preventative framework. Insights from across the profession will help:
- evidence the robustness of UK sanctions compliance;
- highlight operational challenges and areas for improvement; and
- inform government understanding of PF risk behaviours, typologies and sector‑specific exposures.
Take part
Please provide your responses via the online survey: https://www.smartsurvey.co.uk/s/L8QU02/
This survey will close on 31 March 2026.
Confidentiality and use of responses
- FATF Mutual Evaluation: responses will form part of the evidence base for the UK’s submission to FATF assessors, demonstrating the effectiveness of UK firms’ implementation of UN-mandated targeted financial sanctions for TF and PF.
- PF National Risk Assessment: responses to the PF NRA section will inform HM Treasury’s analysis and conclusions in its forthcoming Proliferation Financing National Risk Assessment publication.
All information provided through this survey will be aggregated and anonymised. It will not be attributable to any specific firm.
Useful resources
Take part in HM Treasury’s survey
Please provide your responses via the online survey.
Respond by 31 March 2026