On 31st July 2025 the threshold amount for submitting a defence against money laundering (DAML) has been increased from £1,000 to £3,000. Certain conditions need to be met. See below:

• The transaction must:
  • take place in the regulated sector
  • involve money or property valued at less than £3,000
  • involve transferring or handing over to the client money or other property which belongs to or is owed to the client
  • be made for the purpose of exiting the relationship with the client.
• The firm must have complied with their duty to carry out CDD.

In the context of the Proceeds of Crime Act 2002 (POCA), a DAML (Defence Against Money Laundering) is a mechanism that allows individuals and businesses to seek consent from the National Crime Agency (NCA) to proceed with transactions that might otherwise be prohibited under POCA due to concerns about handling criminal property. Essentially, a DAML is a request for "appropriate consent" from the NCA to avoid committing a money laundering offense when dealing with potentially tainted funds. The threshold is specifically designed to reduce low-value Suspicious Activity Reports (SARs) and streamline law enforcement efforts.

If you need help with AML & POCA:

AML & Sanctions Training: https://hunningsconsultancy.co.uk/aml-training-when-are-you-required-to-do-this/

Independent AML Audit: https://hunningsconsultancy.co.uk/independent-aml-audit/

Practice or Firm Wide Risk Assessment Review: https://hunningsconsultancy.co.uk/aml-review/

Help with an SRA AML Audit or inspection: https://hunningsconsultancy.co.uk/sra-audits-inspections-assistance/