On 15 October 2015, HM Treasury published the national risk assessment (NRA) which aimed to identify the UK’s money laundering and terrorist financing risks, inform the efficient allocation of resources and mitigate those risks. The key findings include:

  • significant intelligence gaps, in particular in relation to “high-end” money laundering where proceeds are often held in bank accounts, real estate or other investments rather than cash; and
  • inconsistency in the effectiveness of the UK supervisory regime including in understanding and applying a risk-based approach to supervision and in providing credible deterrence.

The NRA concluded that the collective knowledge of UK law enforcement agencies, supervisors and the private sector of money laundering and terrorist financing risks is “… not yet sufficiently advanced”.