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Anti-Money Laundering & Financial Crime Prevention
Lesson 2: The Regulatory Landscape
UK regulations, POCA, FCA expectations, FATF, and the Barclays AML framework
UK Law
The UK's AML Legal Framework
  • Some of the toughest AML laws in the world
  • Understanding them is not optional — it is a legal obligation
POCA
The Proceeds of Crime Act 2002
  • The foundation of UK money laundering law
  • Creates the criminal offences that make laundering prosecutable
POCA
Principal Offences: Sections 327–329
  • Concealing criminal property
  • Arranging to handle criminal property
  • Possessing criminal property
14 yrs
maximum penalty
POCA
Failure to Disclose: Section 330
  • If you suspect laundering and say nothing, that is a criminal offence
  • Applies to every person in the regulated sector
5 yrs
imprisonment
POCA
Tipping Off: Section 333A
  • Telling someone a SAR has been filed about them
  • A careless word to a client can be a criminal act
2 yrs
imprisonment
Regulations
Money Laundering Regulations 2017
  • Risk assessments for every client relationship
  • Customer due diligence at onboarding and beyond
  • Ongoing monitoring of transactions
  • Record keeping for at least five years
Regulations
2025 Amendments
  • Enhanced due diligence narrowed to FATF Call for Action countries
  • Crypto firms brought into closer regulatory alignment
  • Changes take effect in 2026
FCA
The FCA's Supervisory Role
  • Supervises 20,000 firms for AML compliance
  • 2026 priority: AML deficiencies = governance failings
  • Increased risk of personal liability for senior managers
International
The FATF Global Standard
  • 40 recommendations across 190+ countries
  • UK rated compliant on 24, largely compliant on 15
Barclays Framework
Three Lines of Defence
  • 1st Line: The business — due diligence day to day
  • 2nd Line: Risk & compliance — frameworks and oversight
  • 3rd Line: Internal audit — testing whether controls work
Barclays Framework
The Financial Crime Policy
1
Financial Crime Policy
11
standards
4
risk areas
  • Since January 2025: principal risk with Board-level oversight
Guidance
JMLSG Industry Guidance
  • Approved by HM Treasury
  • Following it offers a safe harbour
  • Generally satisfies the regulator that obligations have been met
Your Obligation
Section 330 Applies to You
  • Know the law
  • Follow the framework
  • Report your concerns
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