HM Treasury AML Supervision Report 2024-25: What It Found

Every year HM Treasury reports on how the UK's anti-money laundering and counter-terrorist financing (AML/CTF) supervisors are performing. Its report for 2024-25 is the most useful single source on how accountancy firms are actually doing against the Money Laundering Regulations: how many firms are supervised, how many are found compliant, which breaches come up most and how much has been fined. This guide summarises the findings that matter to accountancy firms. It is general information, not legal advice. The report is HM Treasury's 13th annual report on AML/CTF supervision, published on 8 December 2025 under regulation 51 of the Money Laundering Regulations, and it covers 6 April 2024 to 5 April 2025. This guide covers the sections we were able to read, which run through HMRC's enforcement figures. It does not cover the professional body supervisors' enforcement detail or the later chapter on cooperation and information sharing.

It pairs with our summary of the OPBAS report on professional body supervisors, which looks at the same system from the supervisors' side.

Who is supervised

According to the report, there were 25 supervisors in 2024-25: the Financial Conduct Authority (FCA), HM Revenue and Customs (HMRC), the Gambling Commission, and 22 legal and accountancy professional body supervisors (PBSs). Together they supervised about 94,891 businesses. The report gives the FCA about 16,000 firms and HMRC 36,782 (28,837 firms and 7,945 sole practitioners). The PBSs supervised 34,352 accountancy businesses and 7,500 legal businesses, and for accountancy about 60% were firms and 40% sole practitioners.

Getting in: applications and refusals

Across all supervisors, the report records 12,888 applications in 2024-25, of which 933 were rejected, and notes that some applicants withdraw before a rejection, so refusals are understated. HMRC alone received 9,524 applications and rejected 485, with refusals highest among money service businesses, trust and company service providers (TCSPs) and high value dealers. HMRC also approved 58,835 applications from beneficial owners, officers and managers and rejected 80. About 9% of the supervised population were categorised as high risk, similar to previous years.

How much supervision happens

The report counts 7,991 desk-based reviews and onsite visits across all supervisors in 2024-25, covering about 8% of firms, down from 10% in 2023-24. It notes that supervisors employed 693 full-time equivalent staff, down from 708, while spending rose by 24% to £57 million. For the PBSs on their own, about 12% of their population received direct supervision, up from 10%. In practical terms, in any year most firms are not reviewed, but a minority are, and the reviews are finding problems.

Compliance outcomes

For accountancy PBSs the report records that 24% of assessed firms were compliant, 59% generally compliant and 17% non-compliant. Non-compliance was 18% for high-risk firms, 22% for medium-risk firms and 11% for low-risk firms. HMRC's outcomes were much weaker, at 19% compliant, 21% generally compliant and 60% non-compliant, although HMRC's population includes sectors such as money service businesses and high value dealers as well as accountancy service providers, so the figure is not an accountancy-only result. The report also warns against comparing supervisors directly, because several of the measures are new and their definitions may change.

The breaches that keep coming up

The report lists the most common breaches as inadequate documented policies and procedures, failure to provide specified information, inadequate client risk assessments, inadequate record keeping, and a lack of knowledge of the regulations, often linked to using templates without tailoring them. This list will look familiar, and it is a useful checklist. Our guide to the firm-wide risk assessment covers the document supervisors most often find missing or generic.

New this year, the report measured repeat non-compliance. About 15% of non-compliant businesses were also non-compliant at their previous assessment. That figure speaks to the question supervisors are now asked: do firms fix what they are told to fix?

Fines and enforcement

The report records total fines of £59.5 million across 1,085 fines in 2024-25, compared with £41.5 million the year before, an average of about £55,000. Most of the total, £52.5 million, was imposed on high-risk businesses, and a small number of large FCA fines, totalling over £49 million across five fines, account for much of it. Across all supervisors, TCSPs attracted about £1 million across 185 fines, and the memberships of 29 TCSPs were suspended or revoked. The report also says 1,100 enforcement actions were published online.

HMRC's own figures are in the same chapter. According to the report, HMRC issued 739 fines in 2024-25, of which 682 were on high-risk businesses, took 798 formal and 947 informal actions, and published 677 enforcement actions. It suspended or cancelled 59 registrations, and 29 of those were accountancy service providers, ahead of estate agency businesses (20), money service businesses (7), and one each for trust and company service providers and telecom, digital and IT payment service providers. HMRC's fines on trust and company service providers were 19 in number, totalling about £132,000. The report also says HMRC closed 632 cases on unregistered businesses and confirmed 204 as trading while unregistered, and that accountancy PBSs identified 89 unregistered businesses and took 107 enforcement actions against them.

For HMRC's approach to penalties and appeals, see our guide to HMRC AML enforcement.

What the report says about reform

HM Treasury says the Government will make the FCA the AML/CTF supervisor for professional services firms, covering the legal and accountancy sectors and TCSPs, with timing dependent on legislation, funding and parliamentary time. The PBSs would keep their wider regulatory roles, and the OPBAS function would end once PBSs lose their AML role. The report also says the Government will measure supervisory effectiveness before and after reform, and that the UK's next FATF mutual evaluation is due in 2028. For what the change means for firms, read our guide to the FCA as single AML supervisor.

What accountancy firms can take from it

These are our suggestions, not requirements in the report:

• Check your own file against the breach list. Policies, client risk assessments, record keeping and information requests are the common failures.
• Tailor your templates. The report links a lack of regulatory knowledge to untailored templates, so make sure yours describe your firm's real clients and services.
• Close findings quickly. With repeat non-compliance now measured, treat any remediation deadline as fixed.
• Do not assume you will be missed. Only a minority of firms are reviewed in any year, but the outcomes show that findings are common when they are.
• Keep the long view. Supervision is changing, and records that stand up to one supervisor should stand up to the next.

Frequently asked questions

Does this report apply to my firm?

It covers the whole supervised system. If your firm is supervised by a professional body or HMRC, the findings describe the environment you are supervised in.

Are the compliance figures reliable for comparing supervisors?

The report itself warns against direct comparisons, because the metrics are new and definitions may still change.

Does 60% non-compliance at HMRC mean accountants are failing?

No. That figure covers all of HMRC's supervised sectors, not only accountancy service providers.