Regulation 2025

Occasionally, I used to joke, "It's Anti Money Laundering, actually," having been introduced as a "Money Laundering Specialist." It always got a chuckle.

Nobody's laughing now.

This isn't a political piece but a practical one, so I shall put aside anything inconvenient, like morality, for example.

The direction of travel, as we are prone to call it, is towards deregulation. Pragmatism is the new buzzword. Bribery? Oh, you mean "Facilitation Payment." Sanctions? Smancshuns.

I don't know any business that feels it needs more anti-money laundering regulation. On paper, many will welcome a more hands-off approach. Customer Due Diligence and its mother, Know Your Customer, are relative newcomers. I worked at Bureaux de Change in the 1980s, where customers would bring carrier bags full of small denomination Dutch Guilders for exchange. They'd been selling in Amsterdam. They may have been selling pencils, but I suspect they weren't. It was none of my business.

Are those days set to return?

Maybe.

These are scary times for AML specialists. Whenever I feel down, I give thanks that at least I'm not in DEI.

As the playing field changes, it will in all jurisdictions. If the US is moving fast and breaking things, so will everyone else.

The machinations of politics, legislation and regulation are above my pay grade, but regulated entities need to be careful not to anticipate loosening rules or enforcement.

HMRC, FCA, and European regulators are not suddenly going to stop supervising. It may be that the emphasis moves away from anti-financial crime, but inevitably, it will take time for an emphasis shift to trickle down into regulations and obligations.