What to Expect in AML, Fraud and Financial Crime in 2026

21 January 2025
All resources, Future of work, Learning and development strategy, Learning topics

Navigating New Laws, Crypto Risk & Corporate Liability in the UK

The world of anti‑money laundering (AML), fraud and financial crime is evolving fast – and 2026 is shaping up to be a landmark year for UK businesses. With new laws, tighter regulation of crypto, and increased regulatory scrutiny, firms must step up compliance, controls, and training. In this article, we outline the key developments that will define 2026 – and what you should do now to prepare.

1. The New “Failure to Prevent Fraud” Offence – Corporate Liability Just Got Serious

From 1 September 2025, under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), the UK introduced a new strict‑liability corporate offence: “failure to prevent fraud.”

What this means

Large organisations – or any subsidiary of a “large organisation” – can be prosecuted if an “associated person” (employee, agent, subcontractor, etc.) commits certain fraud offences that benefit the business, and the business lacked “reasonable fraud prevention procedures.”
The definition of “large organisation” includes thresholds such as > £36 million turnover, > 250 employees, or > £18 million in assets.
Importantly, liability does not depend on proving that senior executives knew about or authorised the fraud – the fact the criminal act occurred and the lack of sufficient prevention measures is enough.

What your business should do now

Undertake a comprehensive fraud-risk assessment, mapping where fraud could occur (sales, procurement, payments, third‑party agents, etc.).
Establish, document, and enforce robust fraud-prevention procedures: internal controls, separation of duties, transaction monitoring, whistleblowing/reporting channels, audit trails.
Ensure regular training for in key compliance topics such as Anti Money Laundering, Anti-Fraud, Anti-Bribery & Anti-Corruption, Financial Regulations, Whistleblowing, Criminal Finances Act & Tax Evasion, Conflicts of Interest, Market Abuse Regulation, and Competition Law.
This should be delivered to all staff – from finance to operations to third-party agents – so everyone knows red flags and whistleblowing reporting responsibilities.
Maintain documentation showing due diligence: if a fraud occurs, records may be used to defend the business.

Because the onus is on the business to prove prevention procedures – the “defence” is the policies and evidence.

2. Crypto & Digital Assets Under New Scrutiny: 2026 Brings Fresh AML Rules

For years, cryptocurrencies and digital assets have posed AML and financial crime challenges. In 2026, these risks become more regulated rather than overlooked.

New legislation coming in 2026

The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 was passed in 2025 and comes into force on 1 January 2026. Under these rules, UK‑based cryptoasset service providers (exchanges, custodial wallet providers, etc.) must:

Perform enhanced customer due diligence (CDD) on users, including collecting identity data where necessary, in line with the sections of the OECD Crypto‑Asset Reporting Framework.
Maintain detailed records for at least five years of all due diligence and transaction monitoring.
Report transaction and user information annually to HM Revenue & Customs (HMRC) – failure to comply may result in financial penalties.

Implications for businesses

If your organisation deals with crypto – directly, or via partners – you’ll need robust Anti Money Laundering (AML) and compliance frameworks.
Outsiders who might previously have ignored crypto risk must now treat it as mainstream financial crime risk.
Traditional AML regimes must be updated to cover crypto transactions, wallet-based transfers, and records/tracing obligations.

3. RegTech, AI & Automation: From Nice-to-Have to Critical Compliance Tools

As financial crime becomes more complex – involving layered transactions, digital assets, international transfers – manual compliance approaches are increasingly insufficient.

Recent studies show adoption of RegTech and AI-driven compliance tools (for AML monitoring, transaction analysis, customer due diligence, and suspicious-activity detection) is rising sharply.

What this means for 2026

Firms should invest in automated transaction monitoring, real-time alerting, and advanced KYC/AML software – especially if they have high transaction volumes or handle cryptoassets.
Training should shift: compliance staff must understand how to use and interpret RegTech tools, and ensure their outputs are fed into governance frameworks.
RegTech can help build the “reasonable procedures” defence under ECCTA, by providing audit logs, documentation, and alert history.

In 2026, technology-enabled compliance is central to robust AML and fraud governance.

4. Supply Chains, Third Parties & Extended Risk – The Wider Crime Ecosystem

Financial crime risk is no longer confined to a business’s own operations. Supply chains, subcontractors, agents and partners can introduce vulnerabilities – especially regarding fraud, money-laundering, and dirty funds.

Under ECCTA and related enforcement guidance, corporate liability extends to fraud or money laundering committed by associated persons, including agents, subsidiaries, and third parties.

What to do in 2026

Conduct due diligence not just on clients, but on supply‑chain partners, agents, contractors and intermediaries.
Build third-party risk frameworks: contractual clauses, regular audits, transparency requirements, documentation, and reporting obligations.
Include supply‑chain and partner risk in your enterprise‑wide risk assessments and training.

This broader approach helps prevent downstream liability and strengthens overall financial crime resilience.

5. Culture, Training & Governance: The Foundation of Compliance

Given all the legal, regulatory, and technological shifts – robust culture, governance, and training are indispensable.

Consider the following as standard in 2026:

Mandatory, regular training not only for compliance teams but for all staff. Topics should cover: fraud risk, AML, crypto risk, third‑party risk, suspicious activity reporting, data‑sharing rules.
Clear governance structures – with board-level or senior‑management oversight, documented procedures, roles and responsibilities, audit trails, reporting lines.
Whistleblowing and reporting channels, independent oversight, and a “speak-up” culture to encourage detection and prevention of suspicious activities.
Periodic risk assessments and audits – not “set and forget.” Continuous review is key.

These elements align with what regulators (Home Office, HMRC, SFO) expect organisations to have in place to satisfy the “reasonable procedures” defence.

6. What to Expect in 2026: Key Trends & Forecasts

Trend	What It Means in Practice
Enforcement of ECCTA “failure to prevent fraud”	Corporate prosecutions, unlimited fines, reputational risk – compliance becomes a board-level concern.
Cryptoasset regulation becomes mainstream	Crypto exchanges, wallet providers and related firms face full AML & reporting obligations – crypto risk must be treated like traditional finance.
RegTech & AI use accelerates	Automated AML monitoring and fraud detection become standard, not optional – organisations need infrastructure + expertise.
Broader supply‑chain risk coverage	Supply‑chain, third‑party and agent-related risks are under scrutiny – due diligence must extend beyond direct operations.
Culture & training becomes critical	Regulators expect documented evidence of training, internal controls and compliance governance, not just policies on paper.

2026 Compliance Readiness Checklist

Conduct a full fraud & AML risk assessment, including crypto and third‑party risks.
Implement and document robust fraud prevention procedures (controls, segregation, reporting, audits).
Ensure cryptoasset dealings are subject to AML and reporting compliance if relevant.
Adopt RegTech/AI-driven AML & fraud monitoring tools, and train staff in key compliance topics.
Extend due diligence and compliance to all supply‑chain partners, agents and third parties.
Introduce company-wide training programmes on AML, fraud, crypto, third‑party risk.
Maintain audit logs, records, governance frameworks and whistleblowing/reporting channels.

Final Thoughts

With new laws, heightened scrutiny and broader asset classes under regulation, businesses must respond with robust procedures, documented evidence, an impactful and effective compliance LMS and continuous vigilance.

Those who adapt early – integrating governance, technology and culture – will not only avoid liability but build resilient, trusted operations ready for the future.

How InfoAware can help

At InfoAware, we specialise in providing impactful and fully customisable online training solutions to help businesses stay compliant in an increasingly complex regulatory environment. Some of our courses include:

Anti-Money Laundering Training: Packed with realistic scenarios and case studies, our AML courses equip your team to identify and address money laundering risks effectively.
Anti-Bribery Training: With gamified learning and real-life scenarios, we help companies mitigate bribery risks and avoid corruption.
Modern Slavery Training: Designed for all levels of your team, our training solutions help organisations address supply chain risks and maintain compliance with modern slavery regulations.

We also offer Moodle LMS solutions to host, track, and report on your training efforts, ensuring your compliance programmes are robust and measurable.

Get in Touch

Partnering with InfoAware ensures you’re equipped with the training, tools, and strategies to navigate this challenging landscape. Stay ahead of compliance trends and build trust with stakeholders by making financial crime prevention a cornerstone of your operations.

You can contact us via our contact form, or email us at info@infoaware.com.