HMT publishes latest NRA of money laundering and terrorist financing risks

HM Treasury has published its latest 2025 National Risk Assessment (NRA) of Money Laundering and Terrorist Financing, offering a comprehensive review of the UK's exposure to financial crime. Building on the 2015, 2017, and 2020 assessments, the 2025 NRA evaluates: (i) the UK's AML/CFT framework and the government's response to the 2020 NRA; (ii) overarching money laundering (ML) risks; (iii) overarching terrorist financing (TF) risks; (iv) sector-specific ML/TF risks under the Money Laundering Regulations (MLRs); and (v) emerging cross-cutting risks outside MLR-regulated sectors.

Key developments of risks since 2020 include:

• Increased convergence between ML and sanctions evasion due to global instability.
• The growing use of financial technologies, such as electronic money institutions, payment service providers, cryptoassets and AI, which enhance criminals' ability to operate covertly.

Persistent risks which remain include:

• High levels of cash-based money laundering through smuggling, cash-intensive businesses, money mules and legitimate channels like Post Offices for inserting criminal proceeds into the banking system.
• Continued exploitation of financial and professional service firms by organised criminal groups.
• The misuse of UK corporate structures by both domestic and international actors to launder large volumes of illicit funds through front companies and complex cross-border arrangements.

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