We analysed HMRC’s anti-money laundering penalties list, published on 10 July 2025. The list shows more than £5.15 million penalties charged on nearly 900 businesses with AML failures re meeting obligations under the Money Laundering Regulations 2017, over the January 1 2024 to March 31 2025 period.

We identified the types of businesses HMRC supervise (it is not all of them out there by a long mile), who have been penalised for their AML failures.

What did we find in the data?

In the 2024-25 data released by HMRC on July 10 2025, we found that there were around 883 penalties charged by HMRC as a supervisor for AML failures, compared to 680 in the previous period (2023-24) — so up by a huge margin.

It is generally understood that agents can operate in this sector without any professional qualifications, which could be the reason for the regulatory breaches being so high. For example, failures to identify and record their clients’ identities and addresses properly, and more importantly, their sources of income and wealth.

We were surprised, though, to see only 15 (three in the previous period) money service businesses and four (12) high value dealers on the list. Equally, only 25 (15) corporate service providers had been penalised. We expected there to be more, but this is positive news and welcomed generally.

Remaining positive, we expect businesses are in general doing more in this regulatory space. Registering sooner, getting better at recording comprehensive customer due diligence records, and instilling robust AML policies and procedures for all their staff to follow.

Readers can make up their own minds as to whether they consider there are even more poor operators out there, and just not picked up by HMRC yet.

Here’s more of the breakdown:

We are not sure what to make about seeing 28 per cent (unchanged) of those AML penalties being charged to ASPs again. Of course there ought not to be any on such a list, as they/we are professionals. However, this statistic highlights a rampant problem in the sector.

However, since these ASPs were not supervised by one of the professional accountancy body supervisors because they were not, for example, ICAEW or CIOT members, does that mean HMRC are cracking the whip unnecessarily and being too harsh?

Perhaps HMRC did not give these ASP businesses enough attention and were being too soft, creating the problem? This is unlikely given the majority of types of failures penalised, explained below.

Or perhaps the businesses were comparatively less professional and experienced; smaller/independents and/or naive even? We will leave that readers to ponder over.

Other interesting findings

• The total penalties charged on these supervised businesses, during the 15-month period concerned, were £5,153,949.
• Some 656, or 74 per cent, of all businesses here were charged the average penalty or lower, which was £5,836.86. That is only marginally more than the year before.The lowest average penalties were for MSB and ASP businesses, £3,151.73 and £4,883.50 respectively — we expected more for the former.
• The highest average penalties, and by far, were for HVD businesses, at £41,059.50. There were only four such businesses (unconnected it seems), but with one of them being fined £139,638 for multiple offences, therefore these average results are skewed considerably.

• After removing that one HVD business from the results, the average penalty appears to have been around £8,200 per HVD business on the list.
• Similarly, there was one AMP business that suffered a penalty of £158,679 — the largest sum across the entire list.
• After these two, which stood out, the next largest penalties were for £52,000.

• Interestingly, the Work Life group (of five companies here) has been charged £96,200, in five penalties. However, they appear to be in the CSP sector according to HMRC, whereas an online search showed that they are in the office rentals and co-working space industry. This may be a mistake by HMRC, unless the businesses were offering regulated services unknowingly or negligently.
• Of all the penalties charged on these businesses, only eight (seven in the previous data period) appealed against the initial HMRC decisions. It is not clear from the information published whether those appeals were partially or completely lost or whether the penalty amounts charged were reduced to what we see. They related to a mixture of breach types and different business types.
• Lastly, almost all 883 penalty records related to “failure to apply for registration at the required time” and/or failing to provide the required information as part of registering for AML supervision — 819 of them in total, which is around 93 per cent.
• This shows either negligence of the highest order, thinking/hoping that HMRC would not catch up with them or them generally not understanding their AML obligations.