Why is Anti Money Laundering Check So Important?

On October 28 2021, the National Crime Agency (NCA) announced that they had filed civil claims against a Chinese mother and two sons in the name of suspected money laundering, and successfully asked them to hand over a London property worth 1.6 million pounds for compensation.

National Crime Agency (NCA) is a law enforcement agency in the UK. This agency is the UK’s leading agency in combating criminal groups. It mainly combats organised crime and economic crime, including human trafficking, weapons and drugs, cybercrime, as well as economic crime across regional and international borders etc.

A woman named Mrs Hajiyeva was previously investigated by The National Crime Agency, they issued her an “Unidentified Wealth Order” (UWO) and asked her to explain and prove the source of her large amount of funds. The lady was unable to explain the legal source of her funds, thus, the National Crime Agency confiscated her luxury house in London.

What is the “Unidentified Wealth Order” (UWO)?

UWO refers to “Unexplained Wealth Order”, which is a court order issued by a British court to enable the target person to disclose the unknown source of wealth. The relevant requirement for issuing an “unknown wealth order” is that the court must be convinced that there are reasonable grounds to suspect that the target person’s known legal source of income is insufficient to enable him/her to obtain such a large amount of funds. After the National Crime Bureau and other law enforcement agencies successfully appeal to the High Court, the assets of people who fail to explain the source of their wealth may be seized and bank accounts may be frozen.

We have discussed in a previous article that many students’ bank accounts were frozen by the National Crime Agency or Police in the name of suspected money laundering due to private currency exchanges. Therefore, we once again remind students studying in the UK to use private currency exchange services carefully and not to be involved in money laundering investigations which could affect their studies. If you want to learn more about what to do if your bank account is frozen because of private exchange, you can click here to view the article.

What is Anti-Money Laundering Regulations (AML)?

Anti-money laundering legislation is a piece of legislation aimed at illegal money laundering. Money laundering refers to the illegal act of converting illegally obtained funds into legal funds or concealing the illegal source of funds. The purpose of the anti-money laundering law is to prevent money laundering activities that conceal and conceal the proceeds of crimes, such as drug crimes, organised crimes, terrorist activities, smuggling crimes, corruption and bribery crimes etc., through various means.

The process of money laundering usually includes the following 3 stages:

  1. Placement: Put “dirty money” into the legal financial system while hiding its source.
  2. Layering: This step is also known as “structuring”. It hides the source of funds through a series of transactions and accounting techniques, and breaks down the funds into small transactions, making money laundering activities difficult to detect.
  3. Integration: After the laundered money becomes legal funds, it is withdrawn from legal accounts and real records, and then large-scale consumption, investment, etc are carried out.

In the United Kingdom, companies must abide by anti-money laundering laws. The anti-money laundering regulations in the United Kingdom stipulate that all industries that involve large amounts of capital must take a series of measures to prevent their businesses from being used for money laundering or terrorist financing purposes. For example, in the gaming industry, the UK government imposes very strict supervision. For casinos and online gambling platforms that do not have due diligence to investigate the source of customer’s funds, the UK gaming regulator – the UK Gambling Commission will enforce penalties.

  1. In April 2020, the UK Gambling Commission (UKGC) imposed a fine of £13 million on Caesars Entertainment (now acquired by Silver Point Capital), which is the largest regulatory fine in the UK. Caesars Entertainment was punished on the grounds that it allowed a VIP registered as a high-risk gambler to place bets without investigating the source of funds, and lost £795,000. It also failed to investigate the source of funds for a lady who claimed to be a waiter and allowed her to bet £87,000. Additionally, allowed a customer to transfer £3.5 million through the casino without investigating the source and destination of funds, etc. In addition to being punished with huge fines, three senior managers of Caesars Entertainment in the UK also had their personal licenses revoked.
  2. March 2021, the British Gaming Corporation (UKGC) fined online casino and sports betting operator Casumo with a fine of 6 million to the Gaming Commission for anti-money laundering defaults in the United Kingdom. The casino operator must investigate the client’s funds. And Casumo caused at least 5 customers to lose a huge amount of gambling money without investigating the source of customer funds.


In addition to the gambling industry, the real estate industry also involves a large amount of funds in every transaction. Therefore, the British government also urges real estate agencies and real estate transaction lawyers to check every client’s funds. Especially funds from abroad, including those from areas with frequent and high-risk terrorist activities and areas with more serious bribery.

At present, the UK’s anti-money laundering laws are becoming more and more stringent for financial service providers. For example, banks will always check the source of any large sum of funds in your account. If you plan to buy a house in the UK, we recommend that you prepare relevant documents and materials in advance and cooperate with a conveyancing solicitor for checking your source of funds. At the same time, we also recommend that you contact your bank manager in advance to avoid the bank from misunderstanding the large amount of money you have transferred for house purchases, which may cause your account to freeze.

If you have any questions about buying a house, investing in the UK and AML investigations, please contact us. Our team speak English, Mandarin, Cantonese, Korean, Russian, Portuguese, Spanish etc.