Research highlights: Between 2021/22 and 2024/25, HMRC issued 1,860 AML fines – a 177% increase over four years – with estate agent businesses hit hardest. London remains the top hotspot, accounting for nearly £1 million in fines in 2024/25 alone. Regulation 56 (failure to register) was the most common breach, making up over 500 fines last year. While the number of fines peaked in 2023/24 at 680, average fine values have fallen from £12,684 in 2021/22 to £5,375 in 2024/25. Despite this, total penalties still topped £3 million annually. The biggest fines were often levied against Money Service Businesses, underlining the high-risk nature of their operations.
HMRC’s crackdown on Anti-Money Laundering (AML) compliance has led to a dramatic rise in fines in recent years, soaring 177% over the past four years. From 198 fines in 2021/22 to 548 in 2024/25, businesses across industries – from estate agents and accountants to high-value dealers and money service businesses – have faced increasing penalties for failing to meet regulatory obligations.
This data-driven analysis breaks down which industries and counties have been hit hardest, the most common compliance breaches, and how the average fine has changed over time. With enforcement tightening, businesses must take action to avoid costly penalties.
Key findings:
- The number of fines issued increased from 198 in 2021/22 to 548 in 2024/25 (+177%)
- London remains the most fined city, with Greater Manchester and the West Midlands emerging as new hotspots
- Estate Agency Businesses (EABs) received the highest number of fines annually
- Regulation 56 (failure to apply for registration on time) of the MLR 2017 was the most common breach
- The total value of fines peaked in 2022/23 at £4.3 million
- Average fine values have decreased, dropping from £12,684 in 2021/22 to £5,375 in 2024/25
Significant growth in HMRC AML fines 📈
The enforcement of AML compliance failures has intensified, with the number of fines soaring from 198 in 2021/22 to 680 in 2023/24, a 243% increase. Year-on-year growth reveals a 119% surge from 2021/22 to 2022/23, followed by a 56% increase in 2023/24. However, the trend shifted in 2024/25, with fines falling to 548 – a 19% decrease from the previous year.
| Year | Number of fines | Growth rate YoY |
| 2021/22 | 198 | – |
| 2022/23 | 434 | +119% |
| 2023/24 | 680 | +56% |
| 2024/25 | 548 | -19% |
London remains hotspot for AML fines 📍
London has remained the most fined city for AML breaches, with total fines nearing £1 million in 2024/25.
Greater Manchester continues to attract growing enforcement attention, increasing from 17 fines in 2022/23 to 30 in 2023/24 and 23 in 2024/25. The West Midlands has also seen consistent scrutiny, with fines rising steadily from 13 in 2021/22 to 41 in 2023/24, and remaining high at 36 in 2024/25.
| Year | Most fined areas | Total fines |
| 2021/22 | London (38 fines) | £445,761 |
| West Midlands (13 fines) | £99,892 | |
| Hertfordshire (10 fines) | £697,334 | |
| 2022/23 | London (125 fines) | £2,340,318 |
| West Midlands (31 fines) | £186,820 | |
| Greater Manchester (17 fines) | £96,683 | |
| 2023/24 | London (201 fines) | £1,348,283 |
| West Midlands (41 fines) | £194,540 | |
| Essex (32 fines) | £162,310 | |
| Greater Manchester (30 fines) | £200,750 | |
| 2024/25 | London (178 fines) | £987,173 |
| West Midlands (36 fines) | £195,050 | |
| Greater Manchester (23 fines) | £132,400 |
Which industries were hit the hardest? 🏭
Estate Agency Businesses (EABs) were the most penalised sector every year, with fines rising from 105 in 2021/22 to 320 in 2024/25 (+204%).
| Year | Most fined industry | Fines issued |
| 2021/22 | Estate Agents (EABs) | 105 |
| 2022/23 | Estate Agents (EABs) | 229 |
| 2023/24 | Estate Agents (EABs) | 396 |
| 2024/25 | Estate Agents (EABs) | 320 |
Other industries experiencing significant fine growth include:
- Art Market Participants (AMPs): +5200% from 2021/22 to 2024/25
- Accountancy Service Providers (ASPs): +102% increase
Most common AML breach: failure to register on time ⏰
Regulation 56 of the Money Laundering Regulations 2017 (MLR 2017) was the most cited breach, accounting for:
- 179 fines in 2021/22 (Avg. fine: £5,609.21)
- 426 fines in 2022/23 (Avg. fine: £6,493.89)
- 648 fines in 2023/24 (Avg. fine: £5,584)
- 519 fines in 2024/25 (Avg. fine: £5,403)
Common violations included:
- Failure to apply for AML registration before providing regulated services
- Operating without approval
- Late renewal or updates to registration
Costliest AML breach 💰
While Regulation 56 was the most commonly breached, the costliest AML regulation breaches in terms of fines issued were related to inadequate risk assessments and failure to establish proper AML controls.
| Regulation(s) breached | Year | Total fine amount |
| 18, 19, 33 | 2021/22 | £420,212 |
| 18, 19, 28, 33 | 2022/23 | £1,489,611 |
| 18, 19, 24, 28, 35, 40 | 2023/24 | £175,701 |
- Regulation 18: (Risk Assessment): Businesses must conduct a risk assessment to identify and mitigate money laundering risks related to their operations, customers, and transactions.
- Regulation 19 (Policies, Controls & Procedures): Firms must establish and maintain AML policies, controls, and procedures to minimise risks, ensuring they are proportionate to the nature and size of the business.
- Regulation 24 (Training): Businesses must provide ongoing AML training to employees so they can recognise and respond to suspicious activity.
- Regulation 28 (Customer Due Diligence – CDD): Companies must verify customer identities, assess risks, and perform due diligence before establishing business relationships or processing certain transactions.
- Regulation 33 (Enhanced Due Diligence – EDD): Higher-risk situations (such as dealing with politically exposed persons or high-risk countries) require enhanced customer scrutiny and additional verification measures.
- Regulation 35 (Politically Exposed Persons – PEPs): Businesses must take extra precautions, including senior management approval and enhanced monitoring, when dealing with PEPs or their close associates.
- Regulation 40 (Record-Keeping): Companies must retain records of AML measures, transactions, and customer due diligence for five years, ensuring they are available for regulatory inspection.
Money Service Businesses (MSBs) and High-Value Dealers (HVDs) were the most affected by failures in risk assessments and AML controls, as their transactions often pose a higher risk for money laundering activities. These breaches highlight the importance of robust AML frameworks, staff training, and regular compliance audits.
Total value of AML fines over time 💷
The total value of fines peaked at £4.3 million in 2022/23 before declining to £3.95 million in 2023/24.
| Year | Total value of fines | Average fine amount |
| 2021/22 | £2,486,120 | £12,684 |
| 2022/23 | £4,309,759 | £9,930 |
| 2023/24 | £3,956,949 | £5,819 |
| 2024/25 | £2,945,298 | £5,375 |
Biggest AML fines issued 🤑
The largest fines in each tax year reflect repeated breaches in AML risk assessments, policies, and procedures:
| Year | Company | Industry | Fine amount |
| 2021/22 | Wahed Exchange Ltd | Money Service Business | £420,212 |
| 2022/23 | Xpress Money Services Ltd | Money Service Business | £1,489,611 |
| 2023/24 | Harvey Nichols & Co Ltd | High Value Dealer | £175,701 |
| 2024/25 | M1 Agency LLP | Estate Agency Business | £52,000 |
Money Service Businesses (MSBs) consistently faced the largest fines, while High-Value Dealers (HVDs) saw the biggest single fine in 2023/24.
Sources 🗂️
- HMRC corporate report: Businesses that have not complied with the money laundering regulations (2024 to 2025)
- HMRC corporate report: Businesses that have not complied with the regulations (2023 to 2024)
- HMRC corporate report Businesses that have not complied with the regulations (2022 to 2023)
- HMRC corporate report: Businesses that have not complied with the regulations (2021 to 2022)
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