The UK’s departure from the European Union (EU) has ushered in significant changes to its Anti-Money Laundering (AML) compliance landscape. For fintech and compliance professionals, understanding these post-Brexit adjustments is crucial to ensure adherence to the evolving regulatory environment.​

The Evolution of the UK’s AML Framework Post-Brexit

Historically, the UK’s AML regulations were closely aligned with EU directives. However, Brexit necessitated the establishment of an autonomous framework. The cornerstone of this shift is the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018), which empowers the UK to impose its own sanctions and AML measures independently of the EU. ​

SAMLA 2018 serves two primary purposes:​

• Sanctions Implementation: It enables the UK to create its own sanctions framework, allowing it to issue sanctions rather than adopting EU or UN models. ​
• AML Measures: It provides provisions for detecting, investigating, and preventing money laundering and terrorist financing, aligning with standards published by the Financial Action Task Force (FATF). ​

This legislative foundation ensures that the UK maintains robust AML controls while tailoring its approach to national interests.​

Key Changes in AML Compliance Requirements

Post-Brexit, several notable changes have emerged in the UK’s AML compliance landscape:​

1. Enhanced Due Diligence (EDD) Measures

With the UK now considered a “third country” by the EU, financial institutions must apply enhanced due diligence when dealing with EU counterparts. This includes more rigorous verification processes to mitigate potential risks associated with cross-border transactions.

2. Beneficial Ownership Transparency

The UK government has intensified efforts to increase transparency in corporate ownership. This includes establishing public registers of beneficial owners to prevent the misuse of corporate structures for illicit activities. Such measures aim to deter criminals from exploiting anonymous company ownership to launder money.

3. Alignment with International Standards

Despite leaving the EU, the UK remains committed to aligning its AML regulations with international standards set by bodies like the FATF. This commitment ensures that the UK’s financial system remains secure and reputable on the global stage.

Recent Enforcement Actions and Case Studies

The UK’s regulatory bodies have demonstrated a proactive stance in enforcing AML compliance. Recent cases highlight the consequences of lapses in AML controls:​

• Simpson Thacher & Bartlett LLP

In March 2025, the US law firm Simpson Thacher & Bartlett was fined £300,000 by the UK’s Solicitors Regulation Authority (SRA) for breaches of AML regulations at its London office. The firm admitted to not having a firm-wide risk assessment between June 2017 and March 2020 and not being fully compliant from March 2020 until February 2023. While these breaches did not result in actual money laundering, they increased the risk, according to the SRA.

• Starling Bank

In October 2024, Starling Bank was fined £29 million by the Financial Conduct Authority (FCA) for inadequate financial crime controls. The FCA found that between September 2021 and November 2023, Starling opened over 54,000 accounts for high-risk customers despite an agreement to restrict such activity. Additionally, Starling’s automated screening system had been insufficiently effective since 2017, leading to several potential breaches of financial sanctions.

Implications for Fintech and Compliance Professionals

These developments underscore the critical importance of robust AML controls within organizations. Fintech companies, in particular, must be vigilant in implementing comprehensive compliance programs that include:​

• Risk-Based Approaches: Tailoring due diligence measures based on the risk profile of clients and transactions.​
• Continuous Monitoring: Implementing systems to monitor transactions in real-time for suspicious activities.​
• Staff Training: Ensuring that employees are well-trained to identify and report potential money laundering activities.​
• Regular Audits: Conducting periodic reviews of AML policies and procedures to ensure effectiveness and compliance with current regulations.​

The post-Brexit era has brought about significant changes to the UK’s AML compliance framework. For fintech and compliance professionals, staying abreast of these changes is essential to safeguard their organizations against financial crime and regulatory penalties. By adopting a proactive and comprehensive approach to AML compliance, businesses can navigate the evolving landscape effectively and maintain the integrity of the UK’s financial system.​