Sophie Jaggard
As Australian lawyers, accountants and real estate agents prepare for AML/CTF obligations from 1 July 2026, they have a rare and significant opportunity to learn from more than two decades of UK successes, failures and lessons and avoid repeating the same mistakes.
Having spent the last 8 months in London leading large-scale financial crime transformation work, a few themes have stood out:
1. Professional services firms don’t operate like banks – and the UK regulatory guidance and RegTech solutions need to better reflect this reality.
These businesses are structured differently (often as partnerships) and are relationship-led, highly bespoke and built on trust, judgement and service delivery. Transaction volumes may be lower than banking environments but the complexity and sensitivity of higher-risk matters can be significantly greater.
2. Technology deployment remains a major challenge.
Some UK professional services firms have been required to stitch together multiple systems and platforms to create a workable compliance infrastructure. This has led to operational friction, governance complexity and poor user adoption.
3. On many occasions, compliance investment has been misdirected towards optimising process and activity rather than to delivering measurable outcomes and meaningful risk reduction.
UK professional services firms still haven’t solved their financial crime compliance challenges – a reminder that combatting financial crime sustainably and at scale is a long-term operational and cultural challenge, not a one-off compliance exercise.
Despite the regulation being in force for two decades, the NCA estimates that over £100 billion is still laundered through or within the UK each year. The UK’s annual compliance bill for financial services alone is estimated at approximately £38.3bn. Yet only a very small proportion of illicit flows are ultimately recovered (some estimate less than 1%).
4. In practice, UK banks are increasingly driving AML/CTF expectations across the ‘gatekeeper’ professions and placing pressure on lawyers, accountants and real estate agents to strengthen and evidence controls. This is playing out in areas such as pooled client account under the UK’s 2026 MLR reforms.
For Australian tranche 2 entities, the UK experience provides a valuable roadmap for what to adopt and what to avoid. There is an opportunity to implement more proportionate, technology-enabled and commercially sustainable compliance frameworks from the outset. Smarter data, automation and AI can also support risk-based decision making, reduce unnecessary compliance burden and improve operational efficiency.
Perhaps Australian professional services firms now have an opportunity to move ahead of legacy overseas models and help shape a more modern, practical and technology-enabled approach to financial crime compliance for non-banks globally.