By AAT Comment Anti-money launderingAAT sanctions for AML breaches26 Mar 2025 AAT imposed sanctions against 75 supervised firms for Anti-Money laundering breaches in 2024, with monetary fines amounting to around £170,000 altogether.AAT issued sanctions for breaches of the Money Laundering Regulations, or for failure to appropriately register for Anti-Money Laundering (AML) supervision.One of the highest fines imposed in the drive to improve standards was £10,000 and expulsion. This was made to a firm where there had been a significant failure to comply with requirements.This follows disciplinary action being taken by AAT’s Professional Standards team. The team is still reporting significant levels of non-compliance during its practice assurance reviews. That means our supervised population may be vulnerable to criminals looking to exploit weak AML controls and procedures, and – deliberately or not – enabling money laundering.The common AML failings are outlined below, alongside the percentage of reviews graded as being non-compliant in 2024.Anti-Money Laundering findingsProportion of breaches identifiedNo written policies, procedures and controls4%No/inadequate initial client due diligence and risk procedures27%No/inadequate ongoing client due diligence and risk procedures16%No periodic review of compliance with AML requirements20%No/inadequate staff training10%No firm-wide risk assessment completed7%Missing criminality checks on Beneficial Owner, Offices and Managers (BOOMs)7%No Person of Significant Control (PSC) procedures8%Unsupervised entity1%All licensed members have a legal obligation to comply with the Money Laundering Regulations. AAT’s Registration and Assurance team will be commencing their AML monitoring reviews for 2025/26 very soon, so prepare by checking your firm has the required AML policies and controls in place, and that they are being used effectively to avoid sanctions being imposed for non-compliance.The key requirements of the legislation and AAT’s guidance and resources to assist our members to comply can be found in the dedicated section of our website.AAT’s AML helpline offers advice on all aspects of complying with the Money Laundering Regulations. To discuss any questions you might have, call us on +44 (0)20 7367 1347 or email [email protected].Ethics and the digital worldVisit the AAT Lifelong Learning Portal to find out more about the ethical impact of digital technologies on you as an accountant (log in to view).Find out more AAT Comment offers news and opinion on the world of business and finance from the Association of Accounting Technicians.