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HM Treasury releases its 2022-2023 AML/CFT supervision review.


HM Treasury has issued its eleventh report on AML/CTF supervision. The report is a comprehensive review that provides detailed information on the performance of AML/ CTF supervisors in the 2022-23 financial year. This report fulfils HM Treasury’s obligation, under Section 51 of the Money Laundering Regulations (MLRs), to publish an annual report on supervisory activity using information requested from supervisors.

Each chapter of the report considers a specific area as follows:-

  • Chapter 2 details each supervisor’s crucial risk-based approach in relation to supervising their population, outlines their supervisory activity and considers information-sharing.
  • Chapter 3 considers supervisors’ use of dissuasive enforcement to promote compliance with the AML/CTF standards among their supervised population.


  1. 10% of supervised firms were considered high risk (in line with previous years); 5.5% of regulated businesses were subject to a desk-based or onsite review in 2022-23. Interestingly, PBS reviewed nearly 10% of their populations.
  2. The FCA found pretty low levels of non-compliance (4% of firms subject to a desk-based review), especially compared to the Gambling Commission, which found that nearly half of firms subject to a desk-based review were non-compliant (and 89% of firms subject to an onsite review!).
  3. The report highlights the varying levels of non-compliance across sectors. For instance, the accountancy and legal sectors reported non-compliance rates of 16% and 17% respectively among firms subject to a desk-based review.
  4. Average fines: FCA - £19.4m, Gambling Commission - £2.8m, HMRC - £7,000 and PBSs - £4,000.
  5. Note that the overall fines dropped from the prior year, but that's driven by the significant fines we saw from the FCA during that period.


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