Economic crime (anti-money laundering) levy

Consultation author

HM Treasury

Our response published

7 October 2020

Executive summary

  • AAT understands and supports the desire to increase investment to combat economic crime and recognises that establishing a consistent, sustainable resource for anti-money laundering (AML) purposes in the UK is paramount. However, the proposed introduction of the levy as a means of achieving this is another financial burden on a sector already under strain. This proposal comes at a time when regulated businesses within the UK are in a state of flux and many are in crisis management, operating in considerable uncertainty.
  • AAT believes anything other than a centralised, single public agency will prove inefficient and problematic. A model involving collection by AML supervisors would add disproportionate administrative burdens and costs on those bodies and risks a lack of consistency. A centralised, single public agency model would ensure greater compliance whilst providing clear accountability and consistency of the collection and enforcement of the levy.
  • AAT understands that calculating the levy rate has demonstrated a challenge in ensuring it is proportionate and reflective of risk, while also being simple to calculate, predictable, and cost-effective to collect and administer. Whilst AAT agrees that revenue should be the basis of any levy model, there must be a clear risk-based structure that backs up any metrics used for calculating the levy rate.
Read our response (PDF)