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.
Garry Carter, ICB Director of AML Compliance, commented “ICB fully supports the work of HMRC in identifying unregulated practices and bringing them into line. These are often individuals and practices that do not have qualifications not therefore eligible for membership and supervision from a Professional Body Supervisor (PBS). I am also pleased to see that HMRC, in line with the PBS, are now also sanctioning those practices that fail to operate AML standards and procedures. This is a welcome move towards ridding the profession of unsupervised practices and is an important step in creating a level playing field for the profession".
ICB supports members to keep on top of their AML obligations to increase awareness and thereby hopefully reducing the need for sanctions and fines. ICB provides a constantly updated library of free resources to its supervised practices – including AML checklists and guidance on maintaining a Whole of Practice Rosk Assessment (WoPRA). It also carries out On-Boarding Verification Interviews (OBVIs) on all Beneficial Owners, Officers and Managers (BOOMs) of all new practices prior to issuing their Practice Licence, in which they are taken through their obligations under both the Anti-Money Laundering and Professional Conduct Regulations. On the rare occasions that practices identify problems, ICB is there to offer a helpful, free support package, including advice via either telephone or email, and comprehensive UKFIU guidance on submitting Suspicious Activity Reports. The ICB Newsletter remains a central source of information and the monthly MLR Monday webinar series are further resources for ICB members.
