Report highlights customer due diligence as the biggest gap in AML controls

ICAEW’s 2024/25 annual Anti-Money Laundering (AML) supervision report shows that 80% of the 1,185 monitored firms were compliant or generally compliant, although 20% were classified as non-compliant. The most common failures remain linked to customer due diligence (CDD), including ineffective risk assessment documentation, poor client identification and verification procedures, and failure to update CDD throughout client relationships. Analysis revealed that larger firms with income over £2 million are more likely to be non-compliant, while recurring causes include lack of understanding of regulations and over-reliance on long-standing client relationships. Despite efforts to improve regulation, ICAEW expressed concern over government plans to transfer supervision to a single body, warning of potential increased costs and regulatory complexity.

Source: adapted from ICAEW, November 2025.