UK Government Publishes Three-Year Anti-Money Laundering Strategy

The Home Office published its 2026 to 2029 anti-money laundering and asset recovery strategy on September 15, backing it with at least £550 million and more than 500 additional enforcement specialists. For the UK anti-money laundering strategy accountants must now plan around, the headline date is 2028-29, when the first accountancy firms begin moving to supervision by the Financial Conduct Authority.

The 101-page policy paper on GOV.UK sets the direction for the UK system over three years. It forms part of the government’s wider approach to economic crime, which the forthcoming Economic Crime Plan 2026 to 2029 will set out in full.

The UK anti-money laundering strategy affects accountants in three ways. Their supervisor is due to change, the Money Laundering Regulations 2017 are due to be reworked, and the suspicious activity reporting regime faces a review that could change what triggers a report. None of those changes has taken effect, and the obligations on firms today are unchanged.

What the UK anti-money laundering strategy commits

The strategy is backed by at least £550 million. Of that, £520 million comes from the Economic Crime Levy, the annual charge on firms supervised under the money laundering regulations. A further £30 million comes from a high streets package announced at Budget 2025.

The levy matters to practices because accountancy firms pay it. The money that funds the new enforcement capacity is partly theirs.

The government says it will add more than 500 law enforcement officers and specialists by the end of 2029. It has not said how many will be warranted officers rather than analysts or forensic accountants.

A new National Financial Intelligence Service will sit within the National Crime Agency. It will bring together the Joint Money Laundering Intelligence Taskforce and Data Fusion work, and it will run alongside the UK Financial Intelligence Unit, which keeps handling suspicious activity reports, before the two merge by 2029.

The strategy sits beside the UK Fraud Strategy, published about six months earlier, and the UK Anti-Corruption Strategy, which was published at the end of 2025 and carries 123 commitments. The National Crime Agency estimates that more than £100 billion is laundered through the UK or UK corporate structures each year.

Security minister Dan Jarvis and economic secretary to the Treasury Lucy Rigby set the stated aim of making the UK a “hostile environment for dirty money”.

Accountants move to the FCA from 2028-29

The structural change in the UK anti-money laundering strategy that matters most to accountants is the planned reform of supervision. The strategy lists reducing the number of anti-money laundering supervisors from 25 to three. The three are the Financial Conduct Authority, HM Revenue and Customs and the Gambling Commission.

Under that plan the FCA becomes the supervisor for legal and accountancy firms. The first of those firms begin their transition in year three of the strategy, 2028-29, and existing supervisors stay responsible until then. Our earlier report on FCA-led AML oversight from 2027 set out the start of that move.

Today the picture is split. Professional bodies including ICAEW, ACCA and AAT supervise their own members, and HMRC supervises firms that no professional body covers. The Office for Professional Body Anti-Money Laundering Supervision, which sits within the FCA, oversees the professional body supervisors and reports on where their enforcement falls short.

Firms that move to the FCA will no longer be supervised by a professional body. That ends the dual role, in which a body both represents members and polices them, that OPBAS has flagged as a barrier to effective action.

HM Treasury has separately responded to its consultation on the duties and powers the FCA would need. The government intends to extend the existing information, inspection and enforcement powers in the Money Laundering Regulations to the FCA’s supervision of professional services firms. It plans to fund that supervision on a cost-recovery basis through fees charged to the firms it supervises.

The enabling primary legislation is in the Financial Services and Markets Bill, with secondary legislation to follow. Fee levels for accountancy firms have not been published.

Firm commitments and open consultations

For accountants, the UK anti-money laundering strategy mixes decisions already taken with items still to be consulted on. The distinction decides what a firm can budget for now.

The settled items are the move of legal and accountancy supervision to the FCA, the creation of the National Financial Intelligence Service, and the completion of the SARs Digital Service. Supervisory risk principles are a policy commitment, due in 2027-28 and implemented through 2029.

The consultations come next. A consultation on reforming the 2017 Money Laundering Regulations is due in 2026-27, with a response in 2027-28 and a draft statutory instrument after that. Consultations on enforcement powers, including action against professional enablers, follow the same timetable.

The government is also weighing a wider regulated perimeter. Property developers, offshore virtual asset service providers, antiques dealers, football clubs and agents, and donation-based crowdfunding platforms are all under consideration. No decisions have been made.

The reviews carry no legal change yet. A review of the suspicious activity reporting regime will consider raising the Proceeds of Crime Act suspicion threshold, with “reasonable grounds to suspect” given as one example. A decision is expected in 2027-28.

A review of how legal and accountancy firms could be integrated into the national financial intelligence system is due in 2026-27. UK accountants will therefore see their role in intelligence sharing tested before their supervisor changes.

For the SARs review, the volumes are large. There were 866,616 reports submitted to the UK Financial Intelligence Unit in 2024-25, and a higher threshold could reduce them. Firms would still need records to justify their decisions, so the paperwork may not fall in step.

What accountants should do before the move

Under the UK anti-money laundering strategy, accountants should treat the next two years as preparation, because the rules stay as they are while the supervisor is replaced. Firms that already hold current firm-wide risk assessments, client due diligence files and training records will carry less risk into an FCA review.

Practices that need a starting point can use the Accountio AML compliance pack, which covers the policies and records a supervisor asks to see. Firms moving checks off spreadsheets can compare tools in the guide to the best AML software for accountants.

Identity verification is consolidating among vendors. The SmartSearch and Credas deal is one example, and it affects which provider a firm contracts with.

Supervision under the FCA will be funded by fees on the firms it supervises, so budgets should allow for a new line. Firms should also expect enforcement to be assessed against a single regulator’s standard rather than against 22 professional body approaches.

The people running the process matter as much as the paperwork. Money laundering reporting officers at mid-tier firms will carry the SARs workload through any threshold change, and a firm that cannot show why it reported or did not report will be exposed whichever test applies.

Criticism and the delivery risk

Steve Smart, executive director of enforcement and market oversight at the FCA, called the reforms a “golden opportunity to strengthen the supervision of professional services”. The regulator will have to build that capacity while it takes in tens of thousands of new firms.

Sal Melki, deputy director for economic crime at the National Crime Agency, said “our foundations are strong, and now the NCA and our partners are driving a systemic shift”.

Veronica Stratford-Tuke, research fellow at the Royal United Services Institute’s Centre for Finance and Security, was more guarded. Her view was that “improvements on paper are not the same as keeping dirty money out of the UK”.

The strategy also places the UK in an international frame. The UK holds the presidency of the Financial Action Task Force for 2026 to 2028 and the G20 presidency in 2027, and it will host an Illicit Finance Summit in December. The EU’s Anti-Money Laundering Authority is due to begin operating in 2028, so firms with clients in the EU will see supervisory models change on both sides of the Channel.

The next dated step is the consultation on the Money Laundering Regulations, due in 2026-27. It is the first point at which accountants can respond to specific proposals on their obligations.