The UK Treasury has launched a formal call for evidence, asking banks, law firms, and other City institutions to submit real-life case studies demonstrating how they have successfully blocked dirty money from entering the financial system. The initiative comes as ministers prepare to showcase the effectiveness of the UK’s anti-money laundering (AML), counter-terrorist financing, and sanctions regimes ahead of a critical 2027 assessment by the Financial Action Task Force (FATF), the global watchdog on financial crime.
Background and Purpose of the Call for Evidence
The Treasury’s request is part of the UK government’s preparation for its upcoming FATF mutual evaluation, which will assess the country’s compliance with international standards on combating money laundering and terrorist financing. The last FATF assessment in 2018 painted a damning picture of the UK’s AML controls, contributing to longstanding allegations that London had become a laundering hub for illicit funds.
In its call for evidence, the government stated it is seeking “real-life examples with clear, demonstrable results that illustrate how the UK’s anti-money laundering, counter-terrorist financing and sanctions frameworks operate effectively in practice.” The submissions are intended to “build the strongest possible picture of system-wide effectiveness” and will form part of the evidence packet the UK will submit to FATF in October 2026. Following this submission, FATF examiners are scheduled to conduct an on-site review in the UK in summer 2027.
What the Treasury Is Asking For
The Treasury has specified that it wants case studies from 2022 onwards, covering a range of scenarios where financial and legal institutions have intervened to prevent money laundering or related financial crimes. Specifically, the government is requesting examples of:
- Instances where firms rejected or terminated relationships with potentially high-risk clients.
- Cases where a company’s internal intervention led to a state investigation or prosecution.
- Situations where red flags for financial crime were identified in customer profiles, and how this influenced the firm’s client acceptance policies.
These examples are meant to demonstrate not only individual successes but also systemic improvements in the UK’s AML infrastructure since the last FATF review.
Stakes and Challenges for the UK
Despite significant investment in AML supervision and enforcement, the UK continues to face substantial challenges in curbing financial crime. The National Crime Agency estimated last year that approximately £100 billion is laundered through or within the UK annually, with City firms inadvertently or deliberately providing services to fraudsters, human traffickers, drug traffickers, and other organised crime groups.
Moreover, the UK’s own national risk assessment has classified the legal sector as “high risk” for money laundering in every assessment since 2017. Moody’s, the credit rating agency, highlighted the disconnect between the resources devoted to AML and the persistent scale of laundering, noting in a 2026 report: “Billions are spent each year in the UK on supervision with hundreds of firms refused entry to the financial system following due diligence, yet an estimated £100bn is still laundered annually.”
Moody’s added that FATF examiners are likely to question “how much of that risk is really being reduced by the UK’s controls, intelligence and enforcement, and how quickly.” This underscores the pressure on the Treasury to produce compelling evidence of tangible progress.
Emerging Threats and Regulatory Context
The UK’s AML regime is also contending with evolving threats, including a surge in AI-driven investment fraud and the growing use of cryptocurrencies, which can obscure the origins of transactions. These developments complicate the task of demonstrating effectiveness to FATF, which evaluates not only existing controls but also a jurisdiction’s adaptability to new risks.
A Treasury spokesperson said: “We take firm and coordinated action across government and industry to crack down on economic crime. We have introduced new strategies, enhanced enforcement capabilities and increased funding designed to disrupt those seeking to abuse the UK economy.” The spokesperson added that engagement with industry on AML matters is routine, and preparations for the 2027 FATF assessment are consistent with this approach.
Industry Response and Implications
The call for evidence places the onus on banks, law firms, accountants, and other regulated entities to document and share their AML successes. While many firms already maintain internal records of suspicious activity reports (SARs) and client due diligence outcomes, the Treasury’s request signals a desire for narrative-driven case studies that can be used to illustrate systemic resilience.
Industry bodies such as ACAMS and the Law Society are expected to circulate the request among members, encouraging submissions that highlight both individual interventions and broader policy changes triggered by AML findings. The quality and quantity of responses could influence the UK’s FATF rating, which in turn affects the country’s reputation as a financial centre and its ability to attract legitimate investment.
Timeline and Next Steps
- August 2026: Treasury issues call for evidence, requesting case studies from 2022 onward.
- October 2026: Deadline for UK government to submit its evidence packet to FATF.
- Summer 2027: FATF assessment team conducts on-site review in the UK.
- Late 2027/Early 2028: FATF publishes its mutual evaluation report, including ratings and recommendations.
Firms wishing to contribute should ensure their submissions are anonymised where necessary, comply with data protection regulations, and clearly articulate the outcomes and systemic lessons learned from each case.