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The purpose of this paper is twofold. Firstly, it highlights areas of disconnect between how the financial services sector in the UK approaches the requirement to evidence source of wealth when conducting customer due diligence; the requirements of the UK’s laws and regulations in relation to evidence source of wealth; and the expectations of the Financial Conduct Authority (FCA) in this regard. It then proposes an alternative approach to evidencing source of wealth.

Semi-structured interviews have been carried out among compliance professionals in UK financial services.

This paper provides rare insight into the anti-money laundering arrangements of UK banks, an area that has not yet been widely researched in the academic literature. It highlights a lack of legal certainty in the UK’s laws and regulation around anti-money laundering and argues that the expectations of the FCA exceed both the letter and the spirit of the laws. It suggests that mixed messages disseminated by the FCA have incentivised banks to shift their focus from financial crime risk (i.e. preventing money laundering and terrorist financing, etc.) towards regulatory risk (i.e. the risk of falling foul of regulatory expectations) and proposes a change to the law and regulatory guidance to enhance the level of legal certainty needed for the law to be effective.

The paper makes suggestions for a more practical and risk-based approach to anti-money laundering compliance and for a much-needed change in the law.

It provides unique insight into the due diligence challenges of financial services firms and argues for the FCA to propagate a more risk-based approach to enhanced due diligence.

This paper aims to show how financial services firms determine whether customer transactions or behaviours meet the threshold for suspicious activity reporting mandated by the Terrorism Act 2000 and the Proceeds of Crime Act 2002, and how suspicious activity reporting is executed in practice.

Semi-structured interviews have been carried out among compliance professionals in UK financial services.

Two issues related to suspicious activity reporting have been identified. Firstly, a widespread misunderstanding about the tipping-off offence under s. 333 Proceeds of Crime Act 2002 has been identified, which appears to be a root cause for poor quality as well as over-reporting of suspicious activity. Secondly, issues related to the notice and moratorium periods used by the UK’s National Crime Agency appear to deter reporting of suspicious activity related to live transactions.

The paper makes suggestions for changes financial services firms and the UK’s National Crime Agency can make to improve the effectiveness of suspicious activity reporting.

The paper provides valuable insights which can be used to limit the flow of criminal funds, improve the quality of suspicious activity reporting and enhance the effectiveness of law enforcement agencies.

This paper aims to propose a new research agenda that integrates the often-overlooked insights and experiences of compliance professionals into anti-money laundering (AML) policy formulation and academic research. It seeks to highlight the importance of a bottom-up approach in developing AML strategies that are not only theoretically robust but also practically effective and grounded in real-world application.

Using a comprehensive literature review and theoretical analysis, this study outlines six broad research focus areas. These areas are explored through the lens of existing theoretical frameworks that underscore the significance of practical insights, interdisciplinary collaboration and adaptive policymaking in enhancing AML efforts.

This paper highlights a significant gap in current AML research and policymaking, namely, the underrepresentation of compliance professionals’ perspectives. It argues that integrating these frontline insights can lead to more nuanced and effective approach to AML.

Adopting the proposed research agenda could significantly enhance the practical applicability of AML policies, leading to more effective prevention and detection of financial crimes. It encourages the development of support systems for compliance professionals, fostering a workforce that is both competent and resilient.

By promoting a more inclusive and practice-based approach to AML policymaking, this paper advocates for a societal shift in how money laundering is tackled.

This paper contributes to the AML discourse by proposing a shift towards a more inclusive research and policymaking paradigm that values the contributions of compliance professionals. It extends the existing literature by suggesting a comprehensive framework for bridging these divides, thereby offering a novel perspective on enhancing the effectiveness of AML strategies.