Cost of compliance with the Money Laundering Regulations - HM Treasury survey for regulated businesses

1. Introduction and survey questions

Thank you for agreeing to take part in this survey, which will support HM Treasury to better understand the cost of compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the ‘MLRs’). This survey is aimed at businesses which are subject to the MLRs.

The information gathered will improve our understanding of costs and help inform future policy development. While we may publish aggregated data or use the resulting cost estimates in future regulatory impact assessments, we will not publish, or make available to other public bodies (including AML/CTF supervisors), any identifiable or firm-level data provided through this survey.  

Please refrain from providing any personal data in the free-text comments sections. Any personally identifiable data provided e.g. email addresses, will be handled in line with the Treasury’s overarching privacy notice for this activity, which is set out at the end of this survey.


Please refer to SmartSurvey’s privacy notice for information on how SmartSurvey will process any of your personal data as the host platform - https://www.smartsurvey.co.uk/company/privacy-policy


Guidance
The questions in this survey should all be answered with respect to your firm’s position at the end of FY2022/23 (or across the duration of the year if relevant). If you cannot answer with respect to FY2022/23, but can answer with respect to another 12-month period (e.g. calendar year 2023), please do so and specify this in your response. Please try to use the latest year possible.

  • If you do not have a precise value for a question, please input an approximate or estimated value.
  • If there is no reasonable approximate available or you cannot answer a question, please leave it blank.
  • If you do not spend time carrying out any one of the actions covered under this survey, you should write zero in the appropriate box.
  • Please keep the main responses purely numerical (or blank) and use only the relevant free-text boxes to provide clarification or to add detail to your responses.


Please submit your responses by 9 June 2024.

If you have any questions/concerns regarding this survey, please contact anti-moneylaunderingbranch@hmtreasury.gov.uk and we would be happy to discuss further.

 

 

1. What is the name of your business? [optional]

 

2. What is your approximate annual turnover? *

 

3. Which regulated sector does your business primarily operate in? *

 

4. If your business operates in any additional regulated sectors beyond the primary sector listed in your answer to the previous question, please list them here.  *

 

5. Which body provides anti-money laundering and counter terrorist financing supervision for your business? *

 

6. Does your business have a dedicated team responsible for ensuring your firm complies with the Money Laundering Regulations? This may include teams which are responsible for other forms of regulatory compliance alongside the MLRs. *

 

7. If you answered ‘Yes’ to Question 6, what is the number of full-time employees or full-time equivalents in this team?

 

8. If you answered ‘Yes’ to Question 6, does this team work on compliance with regulations other than the Money Laundering Regulations? If so, please use the comment box to provide additional information.

 

9. Are you able to provide an estimate for total annual staffing costs related to compliance with the Money Laundering Regulations? If so, please provide it. This should include all identifiable recurring costs including salary, training, equipment, and office space. Please use the comment box to provide additional information or caveats.

 

10. Do you use a transaction monitoring system, or other forms of specialised technology to carry out compliance measures? If so, please use the comment box to list the types of technology used and to provide an estimate of their annual cost. *

 

11. In the previous reporting year, in respect of how many new customers did you undertake due diligence? This should include new and occasional customers only, excluding existing customers with whom you maintain a regular business relationship. If possible, please answer under the following categories according to your assessment of the customer's AML/CTF risk, using the comment box to provide additional information or caveats.

 

12. If possible, can you provide an estimate of the average per-customer cost (or total annual cost, if a per-customer figure is not possible) for the following types of AML/CTF due diligence:

 

13. If possible, can you provide an estimate of the average per-customer cost (or total annual cost, if a per-customer figure is not possible) of ongoing monitoring of existing/regular customers which are:

 

14. Does your firm reflect additional compliance costs for enhanced due diligence in your pricing or fees for high-risk customers (i.e. differential pricing)? If so, please use the comment box to explain how this is calculated. If not, please use the comment box to explain why.

 

15. Would you be willing to answer follow-up questions about your response to this survey, or participate in further discussions or studies on compliance costs? If yes, please provide a contact email address. *

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