On 15 September 2026, the UK Government published its anti-money laundering and asset recovery strategy for 2026-2029 ("the Strategy").

While not a wholesale overhaul of the UK's anti-money laundering ("AML") framework, the Strategy is aimed at making the existing system more intelligence-led, more targeted and less burdened by activity perceived by enforcement authorities as purely compliance driven. It sets a direction of travel rather than a final destination, and businesses should expect further consultations and policy announcements. Here are the key points arising from the Strategy for businesses operating in the regulated sector for AML purposes.

National Financial Intelligence Service and increased headcount

The release of the Strategy coincides with announcements by the Government about the creation of the National Financial Intelligence Service ("NFIS") within the NCA, bringing together work done to date as part of the Joint Money Laundering Intelligence Taskforce ("JMLIT") and Data Fusion initiatives. It is proposed that the NFIS will initially run alongside the UK Financial Intelligence Unit ("UKFIU"), which will retain responsibility for receiving and analysing Suspicious Activity Reports ("SARs"), before the two are integrated into a single national capability by 2029. The stated aims of the NFIS are to identify criminal networks earlier, support live investigations, and enhance disruption and asset recovery.

500 new officers dedicated to AML enforcement, in addition to the 475 financial crime investigators recruited under Economic Crime Plan 2, are promised by the Strategy. It remains unclear whether the new roles will comprise warranted police or NCA officers or, perhaps more likely, a broader mix of personnel across law enforcement with expertise in forensic accounting, digital investigations, data analytics and AI.

SAR reform

The Strategy contains a somewhat ambiguous commitment to "examine the evidence base for raising the suspicion threshold (for example to 'reasonable grounds to suspect')". The principal aim of this suggestion seems to be to reduce the number of SARs filed while increasing their intelligence and evidential value, but the Strategy also refers to the potential benefits of these changes and others it proposes in terms of removing unnecessary regulatory friction.

Exactly what "raising the suspicion threshold" may look like remains unclear. The current law on reporting for those operating in the regulated sector already prescribes a test containing an objective element: SARs are required to be filed where there are "reasonable grounds for knowing or suspecting that another person is engaged in money laundering". However, the test for whether it is necessary to file a SAR also contains a subjective limb, meaning that SARs are also required where individuals do in fact "know or suspect that another person is engaged in money laundering". This requires only a belief that there is a "more than fanciful" possibility that the relevant facts exist. Dispensing with this subjective part of the test could materially reduce the numbers of SARs filed, but would not necessarily reduce the compliance burden on regulated firms. For example, in many cases, more detailed analysis would be required to establish and record relevant facts, why they gave rise to suspicion and why such suspicion was objectively justifiable.

Information sharing

The Strategy refers in general terms to a general aspiration of improving information sharing both between and within each of the public and private sectors. However, one area on which it is silent is how businesses' lingering concerns about the use of existing mechanisms for information sharing within the private sector may be addressed.

Section 188 of the Economic Crime and Corporate Transparency Act 2023 ("ECCTA") permits firms in the regulated sector to share customer information for preventing, detecting and investigating economic crime. Many firms remain cautious, particularly where information falls short of a clear suspicion threshold or concerns about customer complaints and litigation exist. Success in this area may therefore depend less on creating new gateways and more on building confidence in existing information sharing channels.

Expansion of the AML regulatory perimeter

The Strategy raises the possibility of bringing additional sectors within the scope of the Money Laundering, Terrorism Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("MLRs"). Property developers, offshore virtual asset service providers, antiques and antiquities dealers, football clubs and agents, and donation-based crowdfunding providers are identified as types of businesses whose activities may justify more onerous AML requirements and more intensive supervision. Changes for letting agents and higher-risk high-value goods dealers are also mooted. No specific proposals have yet been made as to which of these sectors may be brought within the AML regulatory perimeter. The Strategy indicates that further consultation exercises may follow to identify whether the MLRs are the most appropriate tool in each case.

International context and what comes next?

The Strategy arrives as firms continue to prepare for the EU's new Anti-Money Laundering Authority ("AMLA"). AMLA is currently developing and testing the supervisory framework that will support the commencement of its functions from 2028. While the institutional approaches being taken in the UK and across Europe vary, a number of common themes can be identified. These include greater use of data and intelligence, enhanced information sharing, more consistent supervision and a stronger focus on risk-based outcomes.

The Strategy is unlikely to be the final word on the shape and direction of AML-related enforcement. The UK is due to host an Illicit Finance Summit in December and currently holds the rotating presidency of the Financial Action Task Force. Further announcements, consultations and legislative proposals may follow as the Government seeks to translate its objectives into operational and regulatory change.