AML Compliance for Other Regulated Firms

Many businesses operate in sectors that are inherently higher risk, subject to specialist supervision, or regulated under different frameworks — yet face the same core expectation: to implement effective, proportionate and well-evidenced AML controls.

The AML Practice supports a wide range of AML-supervised and regulated firms, helping them meet existing obligations and maintain confidence when dealing with supervisors, auditors and regulators.

We commonly support firms including, but not limited to:

• High Value Dealers (HVDs)
• Casinos and gambling businesses supervised by the UK Gambling Commission
• Estate agents and letting agents
• Other specialist or niche businesses subject to AML supervision
   

If your business is supervised for AML purposes, this page is for you.

Note, if you provide one of the services listed below, you may want to refer to our FCA Annex 1 page:

• Invoice Finance & Factoring
• Corporate & Trade Finance
• Money broking
• Safe-custody services
• Certain investment-related services

AML supervision in the UK is sector-specific, with different regulators and supervisors applying the Money Laundering Regulations in different ways. However, expectations are increasingly aligned around a common set of principles:

• Risk-based decision making
• Strong governance and accountability
• Effective implementation of controls
• Clear evidence of oversight and review

Whether your supervisor is a statutory regulator, a sector-specific body, or a government authority, the direction of travel is clear: firms must be able to demonstrate compliance, not simply assert it.

For firms regulated under FSMA, this includes oversight by the Financial Conduct Authority, with an increasing focus on AML governance, controls and outcomes alongside prudential and conduct requirements.

Across all AML-supervised sectors, firms are expected to be able to evidence:

• A firm-wide risk assessment that reflects actual business activity
• Clear, documented AML policies, controls and procedures
• Appropriate customer due diligence (CDD) and enhanced due diligence (EDD)
• Effective ongoing monitoring
• Clear AML governance, including MLRO or AML lead responsibility
• Regular, documented AML training
• Periodic review and independent challenge of AML arrangements

The exact emphasis may vary by sector, but the underlying expectations are consistent.

We review your existing AML framework against current supervisory expectations for your sector, identifying gaps, weaknesses and areas of regulatory risk.

You receive a clear, practical report with prioritised remediation actions.

We carry out AML audits and independent reviews designed to assess both design and operational effectiveness, tailored to your business model and regulatory context.

Outputs are suitable for internal governance, supervisory engagement or third-party assurance.

Where applicable, we support firms with:

• AML registration and onboarding
• Preparation for supervisory engagement
• Responding to regulatory queries or feedback
• Ensuring documentation aligns with supervisory expectations

We support firms with annual attestations of AML compliance, helping to evidence that:

• Controls remain appropriate and effective
• Risk assessments have been reviewed and updated
• Policies and procedures remain current
• Training obligations have been met

This creates a clear annual compliance record.

We develop bespoke AML policies and procedures tailored to your sector and risk profile.

Where appropriate, firms also receive access to templated AML documents, enabling efficient updates as regulatory expectations evolve.

We deliver practical, role-specific AML training tailored to your sector, covering:

• Relevant money laundering typologies
• CDD and EDD expectations
• Ongoing monitoring and escalation
• SAR decision-making and AML governance

Training is fully documented and suitable for supervisory review.

We offer flexible ongoing AML support, which can include:

• On-hand ad-hoc AML advice
• Support with higher-risk customers or transactions
• Periodic reviews of AML documentation
• Monthly AML newsletters covering regulatory developments
• Ongoing support tailored to your business and risk profile

Support can be scoped to include any or all of the above.

We support regulated firms in a way that is:

• Risk-based and proportionate
• Aligned to sector-specific supervisory expectations
• Focused on evidence and real-world implementation
• Practical, clear and regulator-ready
• No one-size-fits-all compliance.

If your business is supervised for AML purposes and you want confidence that your framework is robust, defensible and fit for scrutiny — even if your sector doesn’t fit neatly into a standard category — we would be happy to discuss how we can help.

Get in touch to arrange an initial discussion or AML health check.