Regulated Sector AML Compliance
Regulated sector AML compliance applies to far more than banks and financial services firms. Is your firm ready for FCA AML supervision?
The Regulatory Landscape for Non-Financial Businesses
Regulated sector AML compliance applies to far more than banks and financial services firms.
The UK Money Laundering Regulations 2017 cover estate agents, gaming operators, high-value dealers, and art market participants.
HMRC supervises many of these sectors directly. Since 2023, its enforcement approach has become more demanding. On-site inspections are more frequent. Penalties are higher.
Supervisors now expect documented, risk-based AML programmes as standard.
Gaming operators face additional oversight from the Gambling Commission. The Commission has introduced specific requirements on source of funds checks and customer interaction frameworks. Many of these requirements now mirror FCA expectations.
Meanwhile, the EU's AML package and the establishment of AMLA will bring further supervisory harmonisation. This extends to non-financial sectors, not just banks.
How AFC, CDOR, and AI Governance Support Regulated Sector AML Compliance
Anti-Financial Crime (AFC)
The AFC framework covers the AML obligations that apply to designated non-financial businesses and professions (DNFBPs) under the FATF Recommendations.
For estate agents, this means customer due diligence on both buyers and sellers. It also means suspicious activity reporting and compliance with the property-specific provisions of the Money Laundering Regulations.
For high-value dealers and art market participants, the focus falls on transactions above prescribed thresholds. In both cases, identifying beneficial ownership is a key requirement.
Cybersecurity and Digital Operational Resilience (CDOR)
Cyber resilience matters to any sector that handles sensitive personal data or high-value transactions. The CDOR framework provides a structured assessment of your operational resilience controls.
It measures those controls against the standards that regulators and supervisors expect. These include the UK's Cyber Security and Resilience Bill and the EU's NIS 2 Directive where applicable.
AI Governance
Automated screening, risk scoring, and customer identification tools are becoming standard practice across regulated sectors. As a result, AI Governance is now a live compliance concern. The EU AI Act covers high-risk AI systems wherever they are used in regulated decision-making. That scope is not limited to financial services.
Building a Proportionate Regulated Sector AML Compliance Programme
Many firms outside traditional financial services operate with leaner compliance teams and tighter resources. Nevertheless, the regulatory expectations are essentially the same.
A structured assessment identifies the specific obligations that apply to your sector. It measures control effectiveness against a proportionate baseline. And it produces clear outputs that you can present to your supervisor.
Aegis Compass scales to the size and risk profile of your organisation. Whether you run a multinational gaming operation or a regional estate agency, the approach is the same: identify your obligations, measure your controls, and prioritise your next steps.
Determine your regulatory position
Whether you're in real estate, gaming, or high-end art dealing, you have AML regulatory obligations.
Call us to see how you shape up against regulatory expectations.