AML enforcement on the rise

In the first installment of our global horizon scanner series, our team consider the growing trend of increased regulatory enforcement relating to anti-money laundering. 

Although there is some variation in these priorities between regulators, we have seen an increase across the board in enforcement actions. We take a look at jurisdictions where there have been significant developments below. The sectors under scrutiny are proliferating – and this is particularly clear in the context of anti-money laundering where we are seeing increased regulator attention in sectors such as decentralized finance and even outside the financial sector, in luxury goods organizations. Developments include the UAE’s new AML law and significant changes to Australia’s AML/CTF regulatory framework. 

Increase in anti-money laundering enforcement

UAE

Following the UAE being delisted from the Financial Action Task Force’s grey list in February 2024, there has been a marked increase in enforcement efforts to ensure the UAE remains off the grey list. This is evidenced by recent legislative reforms, the creation of specialist courts and increased fines and sanctions. Recently, regulators in the UAE have imposed large-scale fines, for example the Central Bank has levied fines of AED370 million (over US$100 million) since the beginning of 2025 across various financial institutions (including international bank branches, exchange houses and insurance and brokerage companies) in a major AML and CTF crackdown.

In October 2025, Federal Decree Law No. 10 of 2025 was introduced. This has brought in a raft of new changes and significantly: a) imposes new personal liability for managers if they are aware of a crime or a crime occurs due to a breach of their duties; and b) introduces a lower evidentiary threshold to prove actual knowledge that funds are criminal proceeds or will be used to commit an offence.

Further reform of the financial regulatory landscape comes with the introduction of Federal Decree-Law No. (6) of 2025 (the New CBUAE Law), a comprehensive new legal framework governing the Central Bank and its regulation of financial institutions and activities. The New CBUAE Law:

• strengthens enforcement mechanisms, raising the maximum administrative fine from AED200 million (~US$55 million) to AED1 billion (~US$275 million); 
• provides the Central Bank with a wider array of administrative and financial sanctions, including the ability in severe cases to revoke licenses and appoint administrators; and
• establishes a "Grievances and Appeals Committee," which offers financial institutions a formal route to challenge Central Bank decisions. Appeals from this committee may be escalated to the Higher Federal Court.

The New CBUAE Law also grants the Central Bank the power to publish details of its enforcement actions, including the names of the institutions and individuals involved. This increased transparency is expected to act as a powerful deterrent against misconduct. Further commentary on the New CBUAE Law can be found in our recent article article.

These changes align with shifts in the legislative frameworks in other jurisdictions, such as the UK, in strengthening investigative and enforcement mechanisms to make it easier to prosecute money laundering, terrorist financing and other offences. and placing greater responsibility on corporates and senior managers to prevent misconduct.

Australia

Australia’s Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Amendment Act) introduces significant changes to Australia’s AML/CTF framework. The reforms aim to simplify, modernize and expand the framework to include real estate professionals and developers, professional services providers including lawyers and accountants and dealers in precious metals and stones (Tranche 2 entities). Since March 31, 2025, it has been a criminal offense to disclose certain types of information to another person, where it would or could reasonably be expected to prejudice an investigation pursuant to Section 123 of the AML/CTF Act. This is known as ‘tipping off.’

The Amendment Act is supplemented by the new Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (the Rules). As of July 1, 2026, Tranche 2 entities will be subject to AML/CTF obligations under the Act and the Rules, expanding the scope of the Australian AML/CTF framework.

This year alone, AUSTRAC, the AML/CTF regulator and financial intelligence unit, has ordered the appointment of an external auditor over a remittance provider, crypto exchange provider, and financial services provider to assess the various companies’ compliance with the AML/CTF Act. The reasons for the appointment of an external auditor varied, but included concerns over inadequate AML/CTF programs, poor suspicious matter reporting and lack of governance and accountability. Together with the upcoming reforms to the AML/CTF framework, AUSTRAC’s close regulation of the financial sector is indicative of a stronger focus on AML/CTF regulation in Australia.

Amsterdam

Anti-money laundering enforcement is a priority in the Netherlands. Traditionally, anti-money laundering compliance was seen as the exclusive domain of financial institutions. However, enforcement authorities are increasingly investigating allegations of money-laundering by non-financial companies. For instance, the Dutch Public Prosecutor’s Office is currently investigating a luxury brand retailer for allegations of money laundering as criminal proceeds were suspected of being funneled through its Amsterdam boutiques through repeated cash purchases.

For guidance on how companies outside the financial sector can take proactive measures against money-laundering risks, please see our related article.

France

A legal presumption of money laundering has been introduced for transactions involving crypto assets with anonymization features. This presumption applies when the conditions of the transaction “cannot have any other justification than to conceal the origin or the beneficial owner of the assets or income.” In practice, this shifts the burden of proof to the party conducting the transaction, who must demonstrate its legality.

Singapore

Against the backdrop of recent high-profile money laundering prosecutions and various legislative amendments imposing enhanced AML/CFT obligations on different industries and sectors, we expect robust enforcement and scrutiny in this space to continue.

The authorities have also been focused on combatting scams and have implemented various measures ranging from imposing stringent obligations on telecommunications companies, as well as on financial institutions to protect customers’ funds, to enhancing the penalties for convicted scammers and their recruiters. We anticipate that the actions of telecommunications companies and financial institutions will be particularly scrutinized by the authorities and the relevant entities will be held to account in the event of any identified lapses.

UK

HM Treasury published a consultation response on October 21, 2025 regarding reforms to the AML and CTF supervisory system, following its June 2023 consultation paper setting out proposed reforms in this area. Having consulted on four possible models for a future regime, HM Treasury has decided to create a single professional services supervisor, which will have consolidated responsibility for anti-money laundering and counter-terrorism financing supervision of legal, accountancy, and trust and company service providers. The FCA will assume this role and will carry out the supervisory functions as part of its remit. A further consultation on the powers that the supervisor should have was launched on November 6, 2025 which proposes, amongst other things, additional information sharing with law enforcement, support for whistleblowing, the power to impose penalties/initiate criminal proceedings on professional services firms and conduct additional gatekeeping checks. This consultation closes on December 24 and we expect to see the outcome in early 2026.

South Africa

South Africa’s removal from the Financial Action Task Force’s grey list in October 2025 followed sustained reforms that have strengthened the country’s anti‑money laundering and counter‑terrorism financing regime.  We see those reforms playing out in day‑to‑day supervision. The General Laws (Anti‑Money Laundering and Combating Terrorism Financing) Amendment Act, 2022 together with amendments to the Financial Intelligence Centre Act, 2001, Companies Act, 2008 and Trust Property Control Act, 1998 has improved beneficial ownership transparency and broadened the universe of “accountable institutions” to include several non-financial businesses and professions. The Companies and Intellectual Property Commission and the Master’s Office now operate beneficial ownership registers for companies and trusts, creating a clearer line of sight into control and ownership.

South Africa’s anti-money laundering regulatory body, the Financial Intelligence Centre (FIC), has assumed its expanded mandate since the 2022 amendments took effect.  According to its 2024/25 reporting, the FIC conducted hundreds of inspections, produced more than 3,000 intelligence reports and supported recent asset recoveries exceeding R140 million, in cooperation with enforcement bodies. At the same time, it has called out persistent compliance gaps, including low filing rates among some accountable institutions. Information‑sharing initiatives have also deepened. The FIC’s Fusion Centre and the Asset Recovery Hub, working closely with the National Prosecuting Authority and its Asset Forfeiture Unit, have improved coordination on complex financial‑crime matters. 

We see a continuing emphasis on data quality and timeliness in reporting, with the FIC deploying artificial intelligence and machine‑learning tools to enhance the quality and throughput of financial intelligence for investigative and forfeiture purposes. Recent administrative sanctions against accountable institutions also underscore a firmer supervisory stance on risk management and compliance controls.