UK anti-money laundering/counter-terrorism financing regulatory and supervisory regime

AAT understands and supports the desire to undertake a full review of the UK’s Money Laundering Regulations, their extent and scope, and the structure of the supervisory regime including the effectiveness of OPBAS as a regulator.

AAT believes that for there to be a true measure of effectiveness and impact there needs to be an agreed framework to determine/demonstrate effectiveness. There is not enough information yet to determine if the current proposed approach to measuring the effectiveness of the regulations and the wider supervisory regime will be appropriate. Without a meaningful "official" effectiveness measure, and in the absence of adequate data to measure crime reduction and prevention objectives, it lacks specificity, measurability, or any clear statement of the impact of policy interventions.