This timeline outlines developments from 1 January 2024 onwards relating to the anti-money laundering (AML), counter-terrorist financing (CTF), and counter-proliferation financing (CPF) legal and regulatory regimes applicable to financial services firms—from a UK perspective. It shows the developments and implementation history of the UK AML, CTF and CPF legislative framework, including amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs), in addition to AML/CTF related developments from HM Treasury (HMT), the Financial Conduct Authority (FCA), and the Joint Money Laundering Steering Group (JMLSG). It also includes supranational AML/CTF/CPF developments from the Financial Action Task Force (FATF), Basel Committee on Banking Supervision (BCBS), International Association of Insurance Supervisors (IAIS), International Organization of Securities Commissions (IOSCO), Egmont Group of Financial Intelligence Units (FIUs) and the Wolfsberg Group. A timeline of relevant future dates can be found in: Key dates for Financial Services—horizon scanner. A full suite of practical guidance relating to AML/CTF can be found in: Anti-money laundering and counter-terrorist

The European Commission has adopted a delegated regulation amending Delegated Regulation (EU) 2016/1675 supplementing Directive 2015/849 (Money Laundering Directive 4 (MLD4)) to reflect recent changes in the Financial Action Task Force (FATF) monitoring list. As of 10 June 2025, Algeria, Angola, Côte d’Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela have been added to the EU’s list of high-risk third countries due to strategic deficiencies in their anti-money laundering and counter-terrorist financing (AML/CTF) regimes. Conversely, Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda and the United Arab Emirates have been removed from the list following significant progress in addressing identified deficiencies. The update requires EU Member States to require obliged entities to apply enhanced due diligence (EDD) measures when dealing with the newly listed jurisdictions. The delegated regulation enters force on the twentieth day following its publication in the Official Journal of the EU (OJ).

The European Parliament’s Economic Governance and EMU Scrutiny Unit has published an in-depth analysis on the future of Anti-Money Laundering (AML) in the EU, focusing on the institutional and legal dimensions of the Anti-Money Laundering Authority (AMLA) within the EU's 2024 AML/Counter-Terrorist Financing (CTF) framework. The briefing examines how AMLA’s creation addresses long-standing fragmentation in EU financial supervision, aiming to ensure greater consistency in AML practices across Member States. It analyses the AMLA's institutional design, legal foundations, and coordination mechanisms with national and EU bodies following the start of its operations in summer 2025.

The Wolfsberg Group has published guidance dated 16 December 2024, outlining the roles and responsibilities of key actors in a payment chain and emphasising adherence to payment transparency standards. This guidance supplements the Group’s Payment Transparency Standards and serves as a reference for payment service providers, regulators, and standard setters. It has also released a collection of frequently asked questions (FAQs) dated 25 November 2024, entitled Defining Digital Assets in an Emerging Financial Crime Compliance Risk Environment, which defines key terms associated with digital assets.

The European Banking Authority (EBA) has published its 2025 Opinion on anti-money laundering and counter-terrorist financing (AML/CTF) risks affecting the EU financial sector. Drawing on data from 52 competent authorities and the EBA’s EuReCA database, the Opinion highlights how rapid innovation, regulatory reform and evolving criminal techniques are reshaping the AML/CTF landscape. The EBA notes that while some sectors have improved their controls, others—particularly those involving emerging technologies—continue to face significant vulnerabilities. It calls for consistent application of the new EU AML/CTF framework and confirms that new Guidelines on sanctions compliance will apply from 30 December 2025.

The Financial Action Task Force (FATF) has published updated guidance on financial inclusion and anti-money laundering (AML) and counter-terrorist financing (CTF) measures. The guidance encourages countries and financial institutions to implement proportionate, risk-based approaches to expand access to formal financial services, particularly for underserved and vulnerable populations. It follows revisions to Recommendation 1 of the FATF Standards, which reinforce the expectation that AML/CTF controls should be applied using a risk-based approach and promote financial inclusion. The guidance introduces a revised assessment methodology to ensure that future evaluations focus on the practical application of risk-based AML/CTF measures.

The latest Financial Action Task Force (FATF) plenary has announced, among other developments, that it has approved revisions to Recommendation 16 of the FATF Standards on strengthening payment transparency, in addition to endorsing new guidance on financial inclusion and the risk-based approach (RBA). The guidance includes approaches to address de-risking and the application of simplified due diligence (SDD). At the same time, the FATF has revised its assessment methodology to bring it in line with changes to Recommendation 1 of its Standards.

The Financial Conduct Authority (FCA) has published finalised guidance (FG25/3) on the treatment of politically exposed persons (PEPs) under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs).  The guidance follows consultation GC24/4 and should be read in conjunction with the FCA’s multi-firm review on the treatment of PEPs, both published in 2024. It confirms that the existing framework remains broadly appropriate, with amendments made to reflect legislative changes and stakeholder feedback. The guidance outlines how firms should apply a risk-based approach to identifying and managing PEPs, including domestic PEPs, their family members, and known close associates.

The Financial Conduct Authority (FCA) has fined Guaranty Trust Bank (UK) Limited (GT Bank) £7,671,800 for serious weaknesses in its anti-money laundering (AML) systems and controls between October 2014 and July 2019. During the relevant period, GT Bank failed to undertake adequate customer risk assessments, often not assessing or documenting the money laundering risks posed by its customers. The bank also failed to monitor customer transactions and business relationships to the required standard. These weaknesses were repeatedly highlighted to GT Bank by internal and external sources, including the FCA, but despite this, GT Bank failed to take appropriate action to fix them.

The Financial Conduct Authority (FCA) has published a revised version of its FG25/3 guidance on politically exposed persons (PEPs) on 15 July 2025. The update clarifies that firms should not treat non-executive board members of UK civil service departments as PEPs for anti-money laundering purposes. This revision adds guidance that was intended for inclusion in the original 7 July 2025 publication.

The Joint Money Laundering Steering Group (JMLSG) has published revisions to Part II Sector 18 (Wholesale markets) of its Guidance. The revisions have been submitted to HM Treasury for Ministerial approval, and may be accessed under the ‘Revisions’ tab.

Ireland-Banking & Financial Services analysis: This article was written by A&L Goodbody’s Financial Regulation Advisory Team. It examines the EU Anti-Money Laundering Authority's (AMLA) consultations on three draft regulatory technical standards (RTS) relating to customer due diligence (CDD), the identification of business relationships and linked transactions, and the application of pecuniary sanctions and administrative measures. It also outlines AMLA's Single Programming Document for 2026-2028, including its priorities for regulatory rulemaking, direct and indirect supervision, financial intelligence unit coordination and the development of EU-wide anti-money laundering (AML) and countering the financing of terrorism (CFT) risk frameworks.