Focus on money laundering and terrorist financing – national risk assessment and NCA system priorities

The July 2025 National Risk Assessment[1] (NRA) sets out the key risks facing the UK in respect of money laundering and terrorist financing, as identified by the Home Office and HM Treasury.

It confirms the increasingly sophisticated methods used by those seeking to access the UK’s financial and other markets for illicit purposes, including the use of new technologies such as AI and cryptocurrency.

Threats and vulnerabilities

The NRA highlights systemic and emerging risks, noting that:

• Retail banking, cryptoassets, legal and accounting professionals and real estate remain highly exposed to misuse by those seeking to launder money.
• Criminals are increasingly using AI, complex offshore structures as well as professional enablers.
• There has been a growth in state-linked threats and kleptocracy.
• Football clubs, schools and universities are identified as being at increased risk of money laundering, together with businesses such as banking, wealth management and electronic money institutions/payment services providers.

Those at risk are encouraged to use a risk-based approach, conduct enhanced due diligence and work on cross-sector collaboration to address evolving typologies.

The NRA also introduces System Prioritisation, a new yearly mechanism to allocate resources against top economic crime threats under the Economic Crime Plan 2023–26. The 2025 System Priorities were published shortly after the NRA and are detailed below.

The system priorities for 2025[2]

System Prioritisation is a new annual mechanism for resource allocation introduced in the UK’s Economic Crime Plan (2023–2026) and outlined in the 2025 NRA. It ranks the most harmful economic crime threats based on national risk, public harm and impact, enabling the Government and law enforcement to focus resources on the most serious threats. This supports targeted enforcement, supervision and public-private collaboration across sectors.

The Priorities are designed to offer particular support to the regulated sector. Published by the NCA, they carry the full endorsement of the FCA. Nine priorities to tackle economic crime are identified – see below – together with examples of how the NCA hopes to work with the private entities in the regulated sector.

1. Professional enablers deliberately, recklessly or negligently assisting with economic crime and sanctions evasion:

The NCA will work with the regulated sector to identify professional enablers along with sectors and services at greatest risk. The sector should focus on high-risk customers and deepen its understanding of sanctions evasion networks, including in relation to Russia, Iran and DPRK. Referrals to the NCA via Suspicious Activity Reports and other fora will be encouraged.

2. Transactions involving Politically Exposed Persons or their enablers:

The NCA expects members of the UK’s legal, private banking, accountancy and wealth management spheres, together with those providing company and family office services, to proactively refer cases of overseas bribery involving PEPs to the NCA International Corruption Unit – going beyond the legal requirements of Suspicious Activity Reporting.

3. Abuse of the cryptoasset system:

The NCA will work with the regulated sector to identify and embed awareness of risk factors indicative of illicit crypto activity. It will encourage information sharing to protect the public and the legitimate use of crypto. This includes engagement to identify the proceeds of crime and the funds of those who have been the victim of fraud. The NCA will establish processes for the freezing and restraint of suspected funds held on Virtual Asset Service Provider platforms.

4. Criminal cash consolidation and cross-border movement of cash:

The NCA will work with the regulated sector to develop an end-to-end understanding of how criminals are laundering cash in the UK, identify relevant stakeholders and thereafter intervene.

5. Money laundering by Organised Crime Groups, particularly those associated with priority jurisdictions (Albania, China, Russia and the UAE):

The NCA will work to understand international funds flow data and explore ways to disincentivise overseas criminal gangs from targeting the UK financial systems.

6. Fraud perpetrated by international offenders against UK victims:

The NCA estimates that over 70% of fraud against UK victims is perpetrated or facilitated from overseas jurisdictions. The NCA will work to develop a framework for the identification of jurisdictions at risk of fraud which impact the UK and share this information.

7. Exploitation of money mules:

Money mules are identified as those who knowingly (or otherwise) assist in the storage or transfer of illicit funds. In 2022, banks identified 39,000 accounts indicative of mule activity. The NCA will work with the regulated sector to understand methodologies used to recruit money mules and consider public communication systems to increase awareness of the risks.

8. Tackling the significant percentage of frauds originating from online platforms and telecommunications services:

The NCA will work to deepen its knowledge through more strategic and tactical intelligence sharing between law enforcement, banks, telecommunications and technology companies and the regulator to assist in targeting financial flows and systems vulnerabilities.

9. Financing of terrorist attacks and terrorist propaganda in the UK:

Terrorist financing in the UK generally covers the individual’s own needs, such as travel or living expenses. Methods such as cryptoassets, money service businesses, electronic money institutions and crowdfunding donation-based platforms are all used to hide legitimate or illicit funding flows for terrorist causes. The NCA will work together with the private sector to share knowledge and expertise regarding the terrorist-financing situation in the UK.

How Gherson can assist

Gherson’s Regulatory, White-Collar Crime and Investigations Team are highly experienced in assisting with corporate compliance and defence matters. If you require help with your anti-money laundering compliance processes, believe that you may need to file a Suspicious Activity Report, have a suspicion that you may have become a victim of money laundering or find yourself under investigation by the NCA, our experts are ready to help.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail, or, alternatively, follow us on X, Facebook, Instagram, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025

[1] National Risk Assessment of Money Laundering and Terrorist Financing 2025 

[2] NCA and FCA publish priorities to combat biggest economic crime threats