More of the Same or Something Different? The UK’s new Anti-Money Laundering and Asset Recovery Strategy

In recent years, economic crime strategies and plans have been ten-a-penny. The latest is the UK’s Anti-Money Laundering and Asset Recovery (AMLAR) Strategy, published by the Home Office and HM Treasury on the 15 September, following the publication of the Anti-Corruption Strategy in December 2025 and the Fraud Strategy in March of this year. The upcoming Economic Crime Plan 2026-2029 will bring the three strategies together when it is published later this year.

The headlines have focused on the 500 new officers across the police, National Crime Agency (NCA) and Crown Prosecution Services (CPS), funded by the Economic Crime Levy. Increased capacity and capability in law enforcement are always welcome but the strategy, structured around three pillars: Target, Integrate and Empower, also sets out a vision for delivering a more risk-based and threat-led approach to disrupting criminal finances.

Less box-ticking, more bite

The AMLAR Strategy arrives at an interesting moment. For years, policymakers have been encouraged to focus on effectiveness rather than technical compliance. With the UK’s upcoming mutual evaluation by the Financial Action Task Force (FATF), that narrative is increasingly front and centre.

In some ways, the AMLAR Strategy takes this discussion one step further, building on the work started under the previous two Economic Crime Plans. Rather than the somewhat nebulous concept of ‘effectiveness’, the strategy has a clear and prominent aim to ‘reduce low-value activity’. This is a welcome recognition that there are some areas where regulation is, or has, driven activity which is, fundamentally, unhelpful, distracting the system from focusing on the areas of highest threat.

The objective of reducing low-value activity should not, therefore, be seen as deregulation per se or about doing less overall but about identifying areas of duplication or that have little impact on the threat and taking an informed and evidence-based decision as to whether activities are worth continuing or whether resources could be re-deployed.

Some of the changes to reporting suspicious activity that have already been made, for example, have meant that firms have been able to free up resource from filing reports that have little value to law enforcement and pivoting them to areas of higher impact, such as investigating cash-based money laundering. There are specific potentially low-value activities that the strategy identifies, such as discrepancy reporting, but there is also a broader commitment to further changes to the Money Laundering Regulations to ensure that the regulations are targeted on higher risk areas, rather than process-heavy compliance.

A smarter system for following the money

One of the other notable commitments in the Strategy is the establishment of a National Financial Intelligence Service (NFIS), designed to be a ‘more proactive and integrated financial intelligence system’, sitting in the NCA, supported by the FCA and overseen by a public-private board. The UK has a strong history of public-private partnerships and NFIS aims to bring together, and build on, existing initiatives such as the Joint Money Laundering Intelligence Taskforce (JMLIT) and Data Fusion, expanding their scope and allowing for better exploitation of data across the system.

With one eye to the upcoming FATF evaluation, we can expect changes to the FIU’s operating model as it operates in parallel with the NFIS in the short-medium term with the longer-term ambition of bringing the capabilities together. That has the potential to fundamentally change the role of the FIU and financial intelligence more broadly in the system.

A familiar playbook with a sharper edge

So, is the AMLAR Strategy more of the same or something different? The answer is probably both. Many of the themes will feel familiar to anyone who has followed UK economic crime policy over the last decade: public-private partnerships, better use of data, more information-sharing and increased operational capability.

What feels different is the explicit focus on reducing low-value activity and the recognition that effectiveness is not necessarily achieved by simply doing more. Whether that translates into meaningful changes in regulatory requirements and supervisory practice remains to be seen, but the strategy signals a welcome willingness to ask what is actually working and, perhaps more importantly, what is not.