HM Treasury Publishes New National Risk Assessment of Money Laundering & Terrorist Financing 2025

The United Kingdom government has published its updated National Risk Assessment (NRA) of Money Laundering and Terrorist Financing, offering a comprehensive update on the threats facing the UK’s financial system. Jointly developed by HM Treasury and the Home Office, the 2025 NRA is an important tool for regulated professionals, including accountants, seeking to understand and respond to evolving risks.

Key findings:

• The UK remains at high risk of money laundering, driven by its global financial centre status, openness to trade, and adoption of new technologies.
• Terrorist financing threats remain, though typically involving low-value transactions and legitimate income sources.
• Criminals are increasingly exploiting new technologies, including cryptoassets, AI, and informal value transfer systems.
• Cash-based money laundering remains prevalent, with Post Offices, money mules, and cash-intensive businesses still being exploited.
• There is growing convergence between money laundering, kleptocracy, and sanctions evasion, particularly in light of geopolitical instability.

David Potts, AIA Director of Policy & Regulation, said “This latest National Risk Assessment is essential reading for all AIA Members. It provides a clear picture of the evolving threats we face and reinforces the importance of a robust, risk-based approach to anti-money laundering. I strongly encourage Members to review the findings and use AIA’s updated guidance to ensure their firms remain compliant, resilient, and ready to respond to emerging risks.”

The accountancy sector remains judged as high risk for money laundering with key vulnerabilities including:

• Wide accessibility and presence in most towns.
• Fragmented services (e.g., payroll, bookkeeping, tax advice) that can obscure the full picture.
• Use of Accountancy Service Providers (ASPs) to provide legitimacy to criminal transactions (e.g., fake invoices, certificates).
• Exposure to cash-intensive businesses, which can mask illicit funds.

Many ASPs also act as Trust or Company Service Providers (TCSPs), which are high risk for money laundering and medium risk for terrorist financing. Key risks include:

• Formation of companies used in layering and obfuscation.
• Use of nominee directors/shareholders to hide beneficial ownership.

The NRA also identifies key emerging risks, including the misuse of artificial intelligence, the growing role of cryptoassets and virtual payment systems, and vulnerabilities in sectors such as education and sports, all of which present new challenges for detecting and preventing illicit finance:

• AI and digital platforms may be used to create fraudulent documents or bypass AML controls.
• Cryptoassets and virtual IBANs are increasingly used in laundering schemes.
• Supply chain risks: Accountants must assess risks when services are provided via intermediaries or to overseas clients.

AIA Members in Practice should ensure they conduct sector-specific risk assessments that reflect the latest findings from the National Risk Assessment (NRA), and implement tailored policies, controls, and procedures suited to their services and client base. Vigilance around the source of funds, particularly in high-risk jurisdictions or complex structures, is essential, along with ongoing monitoring of client activity beyond initial onboarding checks.

AIA recommends that Members:

• Update Risk Assessments: Incorporate the 2025 NRA findings into the firm-wide risk assessment.
• Strengthen Internal Controls: Ensure staff are trained and systems are robust against emerging threats.
• Engage with Supervisors: Stay informed through AIA guidance.
• Report Suspicious Activity: Use SARs effectively to flag potential ML/TF concerns.

 
Further resources for AIA Members in Practice:

Full National Risk Assessment 2025 Report AIA AML Guidance

“This latest National Risk Assessment is essential reading for all AIA Members. It provides a clear picture of the evolving threats we face and reinforces the importance of a robust, risk-based approach to anti-money laundering."

David Potts, Director of Policy & Regulation, AIA