HMRC has published its AML fines for the first and second quarters of the 2025/26 year. In that period, 124 Accountancy Service Providers (ASPs) were fined a total of £599,656.
Firms and individuals received fines ranging from just over £1,000 to the biggest fine at £52,000, and cover a wide range of breaches, from failure to register to failure to maintain proper AML controls.
Many of the fines are the result of what is known as ‘Policing the Perimeter’, which is where HMRC and the Professional Body Supervisors (PBS), such as ICB, work together to identify those individuals and practices operating without supervision, and which often do not have in place appropriate AML controls and procedures. The fines levied by HMRC and the PBS vary depending upon the length of time that the practice has been operating unsupervised, whether it has been carrying out due diligence on its clients, and generally how the practice cooperates in establishing proper AML controls and procedures.
In the case of ICB, members are charged the current annual fee for every year that the business has been operating and should have been supervised, plus a further fine based on what procedures are either missing or not to the required standard. Where an applicant is unable, or unwilling, to prove from what date they began to operate, ICB charges the fee for every year from 2009, the year that fines were first introduced. There are potentially other sanctions, and in some cases an application is rejected and the member is excluded.
Details of how HMRC applies fines for non-compliance, including the latest list of fines, can be found here: Money laundering supervision sanctions and appeals - GOV.UK.
