This is the UK’s 4th NRA, jointly developed by HM Treasury and the Home Office, drawing upon information collected by the Government, supervisors, including ICB, law enforcement agencies, and the private sector. This updated assessment takes account of the latest developments and information since the previous publication in 2020.
The NRA is an essential tool in ongoing efforts to tackle money laundering and terrorist financing, providing a clear and comprehensive assessment of the current and emerging threats. It sets out how criminals try to move illicit funds through the UK and the risks this poses.
The findings of the NRA are intended to equip government, law enforcement, supervisors, and regulated businesses with up-to-date risk information to enable them to take a proportionate, risk-based response to evolving threats. This helps to ensure a competitive and secure environment for business and investment.
Over the coming weeks, ICB will absorb this information into its AML policies and any changes to our instructions to you will be made clear. ICB will embed appropriate changes into its AMLOnline platform but will ensure that you are made aware of any changes. A future MLR Monday webinar will be devoted to risks that are likely to affect you, as bookkeepers, and will demonstrate how this fits within the broader context of the ICB AML support.
The NRA highlights both the progress made in strengthening the country’s defences and the evolving nature of the risks that are faced. Since the previous assessment, the government has further enhanced its response through significant reforms, including the Economic Crime Plan 2 2023-26, expansion of public-private partnership working and legislative reforms.
Government’s determination to tackle money laundering and terrorist financing remains steadfast. In preventing funds from facilitating crime or reaching those who will threaten the UK’s national and economic security, government will work to ensure that criminal networks and terrorists are deprived of the resources they need to operate, allowing Britain to be a safer, more prosperous place to work and live.
Headline findings in the report
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The UK continues to be exposed to a high level of money laundering risk. Since 2020, the wider context has shifted due to increasing global insecurity, which has altered the risk landscape and the methodologies used by criminals.
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There is growing convergence between money laundering, kleptocracy, and sanctions evasion. Sanctioned entities and individuals have sought to obscure links to their funds by exploiting established money laundering networks.
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The increasing role of new technologies has contributed to the development of new methods of money laundering and terrorist financing, increasing the risk in these sectors with criminals and terrorists seeking to take advantage of these evolving tools and platforms to move and conceal illicit funds.
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The terrorist financing threat in the UK continues to be characterised by low levels of funds, often raised for basic living costs, low sophistication attacks, or for sending overseas for terrorist causes.
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Terrorist financing continues to exploit a wide range of mechanisms, both illicit and legitimate, increasing the potential for regulated sectors to be used to generate, store, move, and access funds for terrorist purposes.
The NRA is important for bookkeepers. Bookkeepers are important for the NRA.
The NRA is a high-level assessment of the UK’s money laundering and terrorist financing landscape. Reading through it, you could be forgiven for thinking that this is way beyond what you, as bookkeepers, are likely to encounter, but it is an extremely important document, and it is vital that you understand the broader risks so that, together, we can ensure that this remains the case. Criminals have a nasty habit of finding loopholes and opportunities.
ICB has created an anti-money laundering framework that helps you see the bigger picture but also provides you with the tools and support to help you make considered judgements that are appropriate and proportionate. Using ICB guidance, including AMLOnline, ICB expects you to be ‘professionally curious’. Your accurate risk assessment and the due diligence you carry out on your clients are the foundation of your business relationship and the trust that you build up with your clients. It is therefore vitally important that you understand the risks you could face, whilst remembering that most businesses are operated by honest people for legitimate purposes.
Because of the services that you offer as a bookkeeper, the depth of knowledge that as a bookkeeper you have of your clients and their businesses and the transactions that you turn into accounts, criminality should stick out to you like a sore thumb. And it is exactly this in-depth and unparallelled knowledge that makes you so important to the fight against not only money laundering and terrorist financing but also fraud and tax evasion.
Unfortunately, there have been occasions when ICB members have encountered criminality, but these are thankfully small in number, but no less concerning and challenging for the members affected. ICB stands by to assist you. If you believe you have identified something that is, or you suspect might be criminality, contact the ICB MLR team immediately for a confidential discussion of your options or just to put your mind at rest.
