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Why AML basics still matter

This month, we examine significant National Crime Agency enforcement operations revealing the persistent threat of cash-based laundering and sophisticated global networks, a major FCA penalty highlighting fundamental control requirements, and key themes emerging from UK Finance’s Economic Crime Conference

High Street crackdown reveals persistent cash-based laundering

The National Crime Agency coordinated raids on over 2,700 UK businesses in a major crackdown on money laundering across high street premises. The operation targeted vape shops, takeaways, and barbershops.

The raids delivered substantial outcomes: more than 920 arrests, over ยฃ10 million in seized cash, frozen bank accounts and criminal assets, and more than ยฃ3.5 million worth of illegal tobacco and hundreds of thousands of illegal vapes removed from sale. Authorities issued over 340 notices for illegal working and rent violations, whilst referring 450+ businesses to Companies House for further investigation.

The criminal activities linked to the raided premises included money laundering, drug dealing, and human trafficking. One jeweller’s shop was allegedly connected to an investment fraud operation.

Despite fraud, synthetic identities, and AI dominating headlines, old-fashioned cash-based laundering remains alive and well on the high street.

What this means for financial crime professionals

Banks and financial services firms need to ensure that their KYC and KYB processes, training and risk assessments remain fit for all types of financial crime.

FCA fines Nationwide ยฃ44 million

The Financial Conduct Authority has fined Nationwide Building Society ยฃ44 million for significant failings in their financial crime controls between 2016 and 2021. The failings encompassed risk assessments, due diligence, and ongoing monitoring.

Nationwide had customers with personal accounts being used for business purposes during a period when the building society did not offer business accounts. These operational arrangements created risk exposure that Nationwide failed to assess appropriately. The organisation did not apply appropriate due diligence and ongoing monitoring to these higher-risk accounts.

The FCA’s final notice gives one example of the risks: a customer’s personal account received fraudulent Covid furlough payments totalling more than ยฃ27 million.

What this means for financial crime professionals

The case highlights fundamental control requirements that financial institutions must maintain, particularly around identifying when personal accounts are being used for business purposes and ensuring appropriate monitoring is applied when risk profiles change.

NCA uncovers billion-dollar laundering network

The National Crime Agency has exposed what they describe as one of the most significant money laundering operations encountered in a decade through Operation Destabilise. The investigation revealed a vast operation where dirty cash from drug dealing, firearms trafficking, and other crimes was collected from towns and cities across the UK by couriers.

The laundering mechanism combined multiple sophisticated techniques. Couriers converted cash into cryptocurrency, which was then moved through a bank in Kyrgyzstan that the network had acquired. Subsequently, the funds were transferred to clients linked to Russia who were subject to sanctions.

This case demonstrates how UK street crime can support global criminal networks, ultimately financing Russian military activity.

What this means for financial crime professionals

The case shows how interconnected these networks are and why firms need monitoring that looks at the bigger picture, not just isolated transactions.

Themes from UK Finance's Economic Crime Conference

UK Finance’s Economic Crime Conference attracted more than 650 attendees. The big themes were collaboration, data sharing under the Economic Crime and Transparency Act (ECTA), and how to use AI safely and effectively.

The industry is shifting towards more proactive, system-wide disruption. ThirdEye’s focus on smarter analytics and clearer insights aligns with what firms are requesting.

What this means for financial crime professionals

Traditional and emerging threats require equal attention: Whilst AI-driven fraud and synthetic identities dominate industry discussions, cash-based laundering through high street businesses remains a significant threat.

Fundamental controls must adapt to actual usage: The Nationwide penalty demonstrates that when customer behaviour diverges from intended account purposes, controls must adapt accordingly.

Sophisticated networks demand sophisticated detection: Operation Destabilise illustrates how modern laundering operations combine traditional cash collection with cryptocurrency, corporate structures, and sanctions evasion.

Industry collaboration drives progress: The themes emerging from UK Finance’s Economic Crime Conference point towards an industry increasingly focused on collaboration, data sharing under ECTA, and intelligent use of AI.

This blog is based on the December 2025 episode of ThirdEye View UK, hosted by Claire Rees and Chris Holmes from ThirdEye. Claire brings over 20 years of financial crime expertise from her experience in financial services as Global Financial Crime Regulatory Specialist, whilst Chris is UK Country Manager supporting ThirdEye clients in the UK since its inception in 2012

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