This week, the UK government published its latest National Risk Assessment (NRA) of money laundering and terrorist financing. The assessment offers a sharp and timely snapshot of how financial crime is evolving—and how the UK is fighting back. As criminals become smarter and more adaptable, the NRA offers a playbook for staying ahead. It is a critical tool for informing the country’s AML policy and regulation, while also giving businesses the intelligence they need to spot risks and protect themselves.

Buy our brand-new UK Country Risk Briefing for further insights into the 2025 NRA and the broader financial crime risk landscape in the UK.

What is the National Risk Assessment?

The NRA draws on a broad range of expertise—from the private sector, academia, and open-source intelligence, to insights from law enforcement, regulators, and across government—to provide a comprehensive and informed picture of the UK’s financial crime risks. It reflects the deep expertise and commitment of partners across both the public and private sectors, including supervisors, regulators and law enforcement, whose efforts are vital to safeguarding the integrity of the UK’s financial system and economy.

What is the Current State of UK AML Regulation?

Since 2020, the UK government has taken significant and sustained action to tackle money laundering and broader economic crime. Central to this effort is the Economic Crime Plan 2023–26 (Economic Crime Plan 2), which sets out a whole-system approach to combatting economic crime. Backed by approximately £115 million in annual funding, the plan builds on the foundations laid by its predecessor and introduces targeted action to address the highest-risk areas identified in the previous NRA.

Combatting corruption and illicit finance is also a key priority within the UK’s foreign policy, given the widespread harm these threats pose to international stability, security, and prosperity. In November 2024, the UK launched its Illicit Finance campaign, aimed at demonstrating global leadership underpinned by strong domestic reforms. The campaign focuses on identifying and addressing the vulnerabilities that enable corruption and illicit finance, both at home and abroad.

Looking ahead, the government is set to publish a new Anti-Corruption Strategy in 2025. This will set out measures to strengthen the UK’s resilience to corruption and reduce domestic vulnerabilities, thus helping to prevent corrupt actors from exploiting the UK’s systems and supporting global efforts to disrupt corrupt networks.

The UK has also continued to deepen its partnerships with other countries, focusing on operational cooperation to tackle shared threats. In addition to providing technical and operational assistance across key jurisdictions, the UK has also invested in strategic partnerships. For example, the UK and UAE are working to deliver on the UK-UAE Partnership to Tackle Illicit Financial Flows. The partnership aims to increase judicial co-operation and align approaches to illicit finance. This includes the work of the Combined Anti Money Laundering Operational Team (CAMLOT), a joint initiative designed to tackle money laundering operations and identify hidden financial networks tied to illicit activities.

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Sector-Specific Risks in the NRA  

The NRA provides a detailed overview of how different sectors are exposed to financial crime risks. It is intended to help firms, supervisors, and stakeholders both within and outside regulated sectors to understand their vulnerabilities and the broader context in which these risks occur.

Each sector’s risk rating is determined using the “MoRiLE methodology”—which assesses the vulnerability of the sector, the scale of the threat, and the effectiveness of current mitigation efforts by both the sector itself and government.

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Key Areas to Watch on the Horizon

AI: A Double-Edged Sword. While the current use of artificial intelligence (AI) in money laundering is not yet widespread, early signs suggest it is already being exploited by criminals in a number of concerning ways. Engagement between law enforcement and the private sector has uncovered examples of AI being used for synthetic bank account creation, phishing and impersonation attacks, and fraudulent onboarding of money mules.

Looking ahead, AI has the potential to supercharge existing money laundering methods. Possible future misuse includes AI-enhanced identity theft, automation of mule recruitment and fund layering, and using AI to identify and bypass AML controls.  

At the same time, AI presents major opportunities to strengthen defences. Financial institutions and law enforcement agencies are already exploring AI-driven tools to detect suspicious patterns, flag high-risk transactions in real time, and improve data analysis. For a deeper look into how AI can be leveraged to combat financial crime, check out our latest white paper on AI and Financial Crime: State of Adoption.

Football: A Growing Target for Illicit Finance. Football is more than just the UK’s national sport—it’s a global economic force. Its financial scale, combined with high visibility and diverse ownership models, makes football an appealing arena for both legitimate investors and criminal actors alike.

While top-tier clubs thrive, many lower-tier and even mid-level clubs face ongoing financial difficulties, often operating under significant debt and pressure to remain competitive. These vulnerabilities create openings for exploitation by individuals and networks seeking to launder criminal proceeds and use clubs to generate further criminal profit. For a closer look at financial crime risks in the football industry, check out our briefing note Foul Play: Financial Crime and the World of Football.

Casino Money Laundering Risks. White-label partnerships in the remote casino sector present notable money laundering vulnerabilities. In the past, some white-label arrangements involved gambling operators relying on unlicensed third parties to handle parts of their compliance responsibilities. While the licensee remained legally responsible for compliance, oversight was sometimes lacking. Although such arrangements are now less common, risks persist—especially when white-label providers manage large numbers of websites. A failure by one remote casino to control money laundering risks linked to their white-label partnerships could affect a wide network of sites.

Moreover, allowing peer-to-peer poker through remote casino platforms also increases money laundering and terrorist financing risks, as it enables direct exchange of illicit funds between customers. The use of VPNs further complicates risk management, as they can mask customers’ true locations. This allows individuals in higher-risk jurisdictions to appear as if they are operating from the UK, undermining geographical risk controls.  

These key watchpoint industries highlight how rapidly evolving technologies and high-value sectors can become flashpoints for financial crime. These risks demand proactive attention, strong regulation, and continued cooperation between public and private sectors to stay ahead of emerging threats.

Discover our UK Country Risk Briefing

For practical, up-to-date insight into the UK’s financial crime landscape, buy and download to explore our brand-new UK Country Risk Briefing. Drawing on the 2025 NRA, FATF evaluations, regulatory developments, and in-house research, the factsheet provides:  

• A threat overview across key financial crime types

• Sector-specific exposure overview with risk rationale

• A regulatory enforcement snapshot

• Key watchpoints for your own risk management

• Real-world examples that illustrate how financial crime typologies play out in practice—and where systemic vulnerabilities are most acute.