Defence Against Money Laundering (DAML) Threshold Triples

The threshold at which businesses can be exempted from committing a money laundering offence has risen. What does this mean for you?

The Proceeds of Crime (Money Laundering) (Threshold Amount) (Amendment) Order 2025, increasing the DAML thresholds in section 339A of POCA £3,000 (previously £1,000), came into force on 31 July 2025.

What does it mean in practice?

The £3,000 threshold is the level below which businesses can be exempted from committing a money laundering offence. However, the transaction must:

• take place in the regulated sector,
• involve money or property valued at less than £3,000,
• involve transferring or handing over to the client money or other property which belongs to or is owed to the client,
• be made for the purpose of exiting the relationship with the client only (if you are unsure whether you are returning money for that purpose, you should seek legal advice), and
• must comply with Customer Due Diligence duties before transferring to a customer/client money or other property.

Your next steps

• Ensure your AML internal policies and procedures are reflecting this change,
• if applicable, ensure your AML relevant staff members are aware of this change,
• if you have knowledge or suspicion of criminal property, regardless of its value, submit a Suspicious Activity Report (SAR),
• remain alert to the potential risk of split transactions that come under the £3,000 threshold.

Learn how to write effective Suspicious Activity Reports with our webinar, FREE to members, running on 2 September 2025 and again on 18 September 2025.

Further guidance and support on Anti-Money Laundering compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email [email protected].

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