Anti-money laundering obligations under the Money Laundering Regulations 2017 (MLR 2017) don’t apply to every UK business — but they apply to more than most people expect. If you carry out any of the activities below, you’re legally required to comply, regardless of your size or turnover.

Who’s in the regulated sector?

• Credit and financial institutions (banks, building societies, credit unions)
• Accountants, bookkeepers and accounting firms
• Auditors and insolvency practitioners
• Tax advisers
• Legal professionals (solicitors, barristers, notaries) carrying out certain transactions
• Trust and Company Service Providers (TCSPs)
• Estate agents and letting agents (high-value rental transactions)
• High-value dealers (accepting £10,000 or more in cash for goods)
• Casinos and other gambling businesses
• Crypto asset exchange providers and custodian wallet providers
• Money Service Businesses (currency exchange, money transfer, cheque cashing)

Under the 2026 reforms, letting agents and art market participants now follow the same CDD rules as high-value dealers — removing an ambiguity that previously left some firms unsure which threshold applied to them.

Sole traders are not exempt

There’s no size or turnover exemption in MLR 2017. A one-person letting agency has exactly the same registration and due diligence duties as a large firm — only the scale of the paperwork differs, not the obligation.

Two routes to supervision

Every regulated business must be supervised by one of two routes:

HMRC registration — the default route for most businesses not covered by a professional body, including money service businesses, high-value dealers, most accountancy and TCSP providers without a recognised body, estate agents, and letting agents handling high-value rental transactions. Registration runs through HMRC’s online portal, and businesses must pass a “fit and proper” test and pay the relevant registration fee before starting regulated activity.

Professional body supervision — if you’re a member of a recognised supervisory body (for example ICAEW or the Law Society), your AML supervision runs through that body instead of HMRC. Check with your professional body before registering separately with HMRC, as dual registration is a common and avoidable mistake.

Beyond HMRC and professional bodies, the FCA supervises banks, investment firms, insurers and crypto asset businesses, and the Gambling Commission supervises casinos and gambling operators. In October 2025, HM Treasury confirmed that the FCA will become the Single Professional Services Supervisor (SPSS)… If your business is currently supervised by a professional body, keep watching for the FCA registration timeline rather than acting early — but expect the switch over the next couple of years.

What happens if you don’t register

Operating in the regulated sector without the correct AML supervision is a criminal offence, not just an administrative gap. It can result in civil penalties, a director ban, or referral for criminal prosecution.