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ARTICLE · 15 OCTOBER 2026

A Shift In Strategy From ‘hygiene’ To ‘hunter’

BCL Solicitors LLP
BCL Solicitors LLP
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BCL Solicitors LLP

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BCL partner John Binns has edited Lexology's comprehensive Anti-Money Laundering guide for 2024, providing expert analysis of AML regulations and compliance frameworks. His work includes critical commentary on AML laws, which he characterizes as weapons of mass distraction in his City AM publication.

United KingdomGovernment, Public Sector

In a divided world, the recommendations of the Financial Action Task Force (FATF), whose 38 members include the UK, US and China (Russia’s membership is suspended), represent a remarkable global consensus on anti-money laundering (AML) strategy. But with Giles Thomson (pictured), director for economic crime and sanctions at HM Treasury, now presiding until 2028, is it time for a rethink?

For those of us familiar with the AML compliance obligations of regulated firms, the task force’s approach of requiring due diligence on clients and transactions, and feeding suspicious activity reports (SARs) into overburdened financial intelligence units (FIUs) clearly has its flaws. For those in law enforcement, the FATF report earlier this year (just before Thomson took charge), stressing the additional work needed to translate SARs into effective asset recovery, risks sounding like a painful statement of the obvious. 

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