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The Payments Association’s response to HM Treasury’s Consultation on Amendments to the Money Laundering, Terrorist Financing and Transfer of Funds Regulations (October 2021)

The Payments Association welcomed the opportunity to respond to the HM Treasury’s consultations earlier this month, including:

  1. Call for Evidence (CfE) – review of the UK’s AML/CFT regulatory and supervisory regime and
  2. Consultation on Amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (information on then Payer) Regulations 2017 Statutory Instrument 2022#


The Payments Association represents members who are regulated under AML legislation i.e. established banks, Challenger banks and Fintechs (including Electronic Money institutions and Authorised Payment Institutions, as well as card schemes and members who are vendors into the payments market, some of which are RegTech companies offering solutions to help prevent financial crime. This is why Project Financial Crime agreed that it was necessary for The Payments Association to submit a response to HMT.

The project team also recognises that sophisticated criminals know how to bypass many of the basic AML controls used today and have identified the vulnerabilities of detection systems implemented by financial institutions. The systems being used to fight back – a combination of technology and human expertise – need to continually evolve and aim to be one step ahead of the criminals who ruthlessly exploit any weaknesses and use the latest technology to achieve their ends.  The government’s ambition should be for the AML/CTF sector to be at the forefront of innovation and technology in the same way as it has that ambition for the payments sector.

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