New AML Regulatory Actions Guidance is now in use

On 7 April, ICAS introduced new guidance on how it will deal with non-compliance with AML requirements.

In January 2025, we informed AML supervised firms that changes were being made to how non-compliance with AML requirements is addressed. 

While most supervised firms have taken an appropriate and effective approach to the requirements, there are still some firms who aren’t doing enough, causing us to take a more robust stance on non-compliance in the public interest. 

The new approach is set out in our AML Regulatory Actions Guidance document, with two main changes for firms to note:

1. Tariffs: The guidance now includes indicative regulatory penalties in response to eight categories of non-compliance, including failures in relation to customer due diligence and firm-wide processes.
2. Timing: To make the process more efficient, AML non-compliance is now being considered by the Committee at the earliest opportunity following identification on a monitoring visit. 

The new guidance is now being used by our regulatory and disciplinary governance bodies, principally the Authorisation Committee, which will consult the guidance when considering the reports from AML monitoring visits. 

Supervised firms are encouraged to review the eight categories of non-compliance in the guidance and take immediate action if there are any areas where further work is required to achieve compliance. More information on common findings from AML monitoring visits can be found in the AML report we published at the end of October 2024.

To further assist firms, ICAS has been increasing the level of AML support which is provided, including articles, videos, and other communications.