Recent AML enforcement data shows that it is not just complex money laundering breaches that are prompting regulators to act. In many cases, it is the basics that are catching regulated businesses out.

Late registration, weak due diligence, poor risk assessments, and gaps in systems and controls are all common failures attracting penalties and sanctions.

We are seeing common enforcement errors across all regulated sectors, including Estate and Letting Agency Businesses (EAB), Accountants and Tax Advisors (ASP), and Trust and Company Service Providers (TCSPs) for exactly these basic issues. And it’s becoming a consistent pattern.

Businesses That Have Not Complied with the Money Laundering Regulations

In the property sector, for example, HMRC’s latest list of non-compliant businesses includes several EABs fined simply for not registering for AML supervision on time. While this may seem insignificant, the fines are not. Recent enforcement data from HMRC showed that some firms were fined tens of thousands of pounds, including one EAB fined £52,000 for falling into that category.

That is not just a minor administrative slip. HMRC is clear: operating as an estate agency or letting agency business without the required AML registration is a criminal offence.

The accountancy sector and those operating as TCSPs are also being penalised for the same issues. The latest figures from HMRC include fines ranging from £1,500 to over £20,000 for failure to register on time.

However, other cases go beyond registration. Examples include:

• A TCSP was fined £7,500 for failures in having the correct policies, controls, and procedures, conducting due diligence, and record keeping.
• An ASP was fined over £14,700 for failures in carrying out risk assessments, having the correct policies, controls, and procedures, and conducting due diligence.

In other sectors, some of the fines were much higher, but the lesson is familiar. A High Value Dealer (HVD) was fined over £139,000 for failures in carrying out risk assessments, having the correct policies, controls and procedures, appropriate staff training, and conducting due diligence (although they have appealed). In another example, an Art Market Participant (AMP) was fined over £158,000 for failures in carrying out risk assessments, having the correct policies, controls and procedures, providing appropriate staff training, conducting due diligence, timing verification, and record keeping.

Regardless of the size of the penalty, there are common failures that link these cases. The recurring themes are late or missing registration, incomplete risk assessments, inadequate due diligence, poor record keeping, inadequate staff training, and compliance frameworks that do not keep pace with the business’s size and risk profile.

HMRC expressly states that its actions can range from warning letters to criminal prosecution, and that financial penalties are meant to be proportionate and deterrent. Since December 2025, a sanctions administration charge of up to £2,000 can also apply alongside any underlying AML penalty.

Compliance Lessons for Regulated Businesses

The practical lesson for regulated businesses is straightforward, but crucial. Here are the key elements that all businesses should check, and not assume are already covered:

• Check whether your business is correctly registered with the right AML supervisor.
• Review your business-wide risk assessment and check that it accurately reflects how you operate today.
• Look closely at how customer due diligence is carried out in practice, not just on paper.
• Check your source of funds processes.
• That your policies, controls, and procedures up to date and relevant to your business.
• Ensure your record keeping is being carried out accurately and consistently.
• Check whether your staff training is up to date and being recorded.

And if your business has grown, taken on new services, or moved into higher-risk work, ensure your controls have been adapted accordingly.

The recent enforcement record suggests that regulators are still finding too many firms getting the basics wrong.

How the Regulation and Compliance Office Supports Regulated Businesses

AML compliance isn’t just about avoiding enforcement. It’s about protecting your business, your team, and your reputation.

If you need help strengthening AML controls, updating documentation, or preparing for HMRC supervision, the Regulation and Compliance Office (RACO) can provide practical, proportionate advice and support.

We can support your regulated business with:

• Review AML policies and procedures to ensure they align with your regulator’s expectations, especially around risk assessments and customer due diligence.
• Train your team to ensure staff understand their obligations, including suspicious activity and reporting.
• Provide outsourced compliance services, including:
  • Outsourced Due Diligence & Risk Assessment: We carry out the due diligence work and prepare risk assessments, so your internal team can focus on review and oversight.
  • Anti Money Laundering (AML) Compliance Service: This support service has been designed to provide AML regulated businesses with an effective solution for the management and control of compliance with the Anti Money Laundering Regulations. Our service is an annual subscription that provides Businesses with ongoing support from our compliance team and ensures your Business has in place appropriate and compliant Policies, Controls, and Procedures (PCP’s) that are maintained by us.
  • Risk, Anti Money Laundering Guidance and Register Administration Service has been designed to provide Businesses and their Money Laundering Reporting Officer (MLRO) with a support function that ensures their regulatory and compliance obligations are fulfilled on an ongoing basis, and staff are provided access to ongoing advice as needed.
  • Regulation 21 Independent Audit. Our service provides businesses with a completely independent audit and ensures the review is completed and reported on in accordance with the regulatory requirements.
  • AML Training. Training staff on the Anti Money Laundering Regulations is a legal requirement. Your staff should understand (and be able to evidence understanding) how the AML rules and the processes the business has implemented to minimise the risk of money laundering.

Our compliance specialists provide practical, sector-specific guidance that enables regulated businesses to meet their obligations without hindering business operations. We work with businesses of all sizes and across all regulated sectors, tailoring our approach to each business’s working methods and risk profile.

Talk to our Compliance Experts 

RACO works with businesses to create the necessary documentation and put the processes in place to ensure the business and its staff are thoroughly protected.

To enquire about our services and how we can service your business, call us on 0203 985 8550 or email us at info@regulationandcomplianceoffice.co.uk

Read other related articles:

• Preparing Regulated Businesses for FCA AML Supervision
• AML Registration Is Not Optional: What Recent HMRC Enforcement Means for Regulated Businesses
• Client Due Diligence: Historic High-Risk Countries – What Regulated Businesses Need to Know
• Estate Agents Under Fire: Over £2.9 Million in AML Fines and What It Means for Your Business