The 2017 National Risk Asssessment of the dangers from Anti-Money Laundering and Terrorist Financing has built on the work undertaken in 2015 to identify where risks have changed and where our understanding of these risks has developed, and to explore in further detail those areas identified as high risk.  

The key findings were:

• High-end money laundering and cash-based money laundering remain the greatest areas of money laundering risk to the UK. New typologies continue to emerge, including risks of money laundering through capital markets and increasing exploitation of technology, though these appear less prevalent than longstanding and well-known risks.
• The distinctions between typologies are becoming increasingly blurred. Law enforcement agencies see criminal funds progressing from lower level laundering before accumulating into larger sums to be sent overseas through more sophisticated methods, including retail banking and money transmission services.
• Professional services are a crucial gateway for criminals looking to disguise the origin of their funds. While intelligence gaps remain in these areas, we have developed our understanding substantially since 2015 and have a better understanding of the specific services and specific types of professional at greatest risk of abuse.
• Cash, alongside cash intensive sectors, remains the favoured method for terrorists to move funds through and out of the UK. The UK’s terrorist financing threat largely involves low levels of funds being raised by UK individuals to send overseas, fund travel or fund attack planning. The primary means of doing this are assessed to be through cash, retail banking or money service businesses (MSBs).

Financial Technologies

The 2017 NRA concluded that the potentail for money laundering and terrorist financing were:

• e-money: medium due to the controls in place and the limited scope to use e-money to launder large sums of money (as evidenced by the few known cases of abuse)
• digital currencies: low, as there remains little evidence of digital currencies being used as an established tool for money laundering, and the money laundering risk is therefore still assessed to be low. However, the link between digital currencies and cyber-enabled crime means that this risk is likely to increase. 

Reforms impact

The report concludes that overall, “A wide-ranging set of reforms by government and law enforcement over recent years is still in its early days, but starting to take effect.” These reforms have included reforms to tackle abuse of professional services, legislation to improve the law enforcement response and measures to improve corporate transparency. In addition, improvements to the public-private partnership have already delivered strong results.