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ARTICLE · 27 OCTOBER 2026

DAMLs And DATFs: Navigating UK Sanctions And AML/CTF Risk

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UK businesses operating in complex markets face overlapping obligations under sanctions, anti-money laundering, and counter-terrorist financing frameworks. When should a company seek formal defence from the National Crime Agency before proceeding with a payment, and what are the critical differences between DAML and DATF mechanisms?

United KingdomGovernment, Public Sector
Daniel Martin
Daniel Martin
Richard Soyoye
Richard Soyoye

Sanctions compliance is currently at the forefront of the regulatory agenda for many businesses operating in complex or conflict-affected markets. However, parallel sets of obligations, under the UK’s anti-money laundering (AML) and counter-terrorist financing (CTF) frameworks, must not be overlooked. Where a transaction raises sanctions concerns, it can also engage obligations under the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000 (TACT). In certain circumstances, a business may need to seek a formal “defence” from the UK Financial Intelligence Unit (UKFIU) within the National Crime Agency (NCA) before proceeding with a payment or transaction.

This briefing explains the circumstances in which a Defence Against Money Laundering (DAML) or a Defence Against Terrorist Financing (DATF) may be required, the critical differences between the two mechanisms, and how sanctions exposure can trigger these obligations.

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