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sentinel. UK AML/CFT for payments rests on the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017), with the FCA as AML supervisor for PIs/EMIs/banks and registered cryptoasset businesses. HM Treasury's July 2025 response confirmed targeted MLR amendments; the 2025 National Risk Assessment (July 2025) keeps the UK at high ML risk with growing payments/cryptoasset/sanctions-evasion exposure. In October 2025 HMT confirmed the FCA will become a Single Professional Services Supervisor. UK prepares for the FATF mutual evaluation scheduled 2027. (Sentinel.gi-fed position; no original illicit-finance analysis performed here.)
Also per Sentinel, the UK's fourth National Risk Assessment (July 2025) keeps the UK at high ML risk, highlighting growing risks tied to payments, cryptoassets, sanctions evasion and new technologies. On 17 July 2025 HM Treasury published its response on improving MLR effectiveness, confirming targeted changes, with draft legislation not yet published; in October 2025 HMT confirmed the FCA will become the Single Professional Services Supervisor; and the UK is preparing for the FATF mutual evaluation scheduled for 2027. The NRA risk rating, forthcoming MLR amendments and the 2027 FATF evaluation together shape the AML compliance burden for payments firms. Further detail and the Sentinel.gi source feed are available via the Sentinel link-out.
Outlook
W11 is stable per the Sentinel feed. The forward horizon carries the UK FATF mutual evaluation scheduled for 2027, against which the UK is preparing supervisory reforms including the FCA's move to Single Professional Services Supervisor, and the still-to-be-published draft MLR amendments following HMT's July 2025 response. Original illicit-finance analysis on these surfaces is out of WPM scope and is flagged to FIM.
AML, CFT & Financial Crime
AML/CFT intelligence for this module is sourced from the Sentinel.gi feed. Readers requiring financial crime analysis relevant to UK payments and cryptoasset activities should consult the Sentinel feed directly at sentinel.gi for authoritative and continuously updated intelligence on illicit finance typologies, sanctions developments, and financial crime regulatory updates.
This cycle's WPM research noted that the FCA will consult in H2 2026 on Financial Crime Guide updates tied to the new cryptoasset regime. The substantive AML and financial crime implications of those consultations are routed to the Financial Intelligence Monitor and to Sentinel; WPM records the forward pipeline date only and does not conduct original illicit-finance analysis.
Outlook
The FCA Financial Crime Guide consultation is expected in H2 2026. Sentinel.gi is the authoritative source for AML/CFT developments in this jurisdiction.
Sources and findings (4)
- T?FIM (sentinel.gi) per-JID baseline profile — United Kingdom — UK AML/CTF regime rests on the Money Laundering Regulations 2017 (as amended), Sanctions and Anti-Money Laundering Act 2018, and Economic Crime and Corporate Transparency Act 2023. OFSI (sanctions), FCA, HMRC and 22 Professional Body Supervisors share enforcement; NCA's Combatting Kleptocracy Cell targets enablers. Reform pipeline (ECCTA ID verification, OFSI penalty overhaul, AML/CTF supervision reform) is active but supervisory fragmentation persists.
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence
- T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-001) — Enforcement: OFSI (HM Treasury) — Sabre Global Technologies Limited (SGTL)
- T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-001) — Sanctions: OFSI listing