AML update – December 2025

What a year that was. Amid the scandals that have surrounded the SRA over Axiom Ince, SSB and the Post Office, a new CEO has taken office and is out and about visiting law firms to understand the lie of the land. In the light of the recent round of ever-increasing fines imposed on most of us for breach of our ML obligations I doubt she will get that good a hearing. And, to cap it all, the FCA is announced as the single professional AML services regulator in place of the SRA.

However, in the meantime, the ‘offensive will continue’ as we try to get our house in order with the increasing burdens and demands imposed on us, notwithstanding some recent attempts to make the system more proportionate.

What do those burdens require, exactly?

Topics covered include:

• What it means to be a ‘gatekeeper’
• SRA position & FCA regulation
• What do we have to do to comply?
  • FWRAs
  • CDD; e-ID&V
  • CRAs
  • MRAs
  • SoW
  • SoF
• What do all the acronyms mean?
• The crucial importance of Ongoing Monitoring