Which Sectors Need AML? High Risk Industries List

Does your business fall under anti-money laundering regulations?

Responsibility for preventing the movement of money resulting from criminal activities isn’t just limited to large financial institutions. In fact, businesses across various sectors are subject to money laundering regulations and must implement Anti-Money Laundering (AML) procedures.

The Financial Action Task Force (FATF), which sets global standards for combating money laundering, identifies specific risk factors that make certain sectors particularly vulnerable to financial crime. But, in short, if your business handles large sums, facilitates asset transfers, or provides services that could be exploited, you need to understand whether AML obligations apply. Not only to protect yourself from financial crime and regulatory fines and penalties, but also to prevent reputational damage.

Even businesses in lower-risk sectors should consider implementing basic AML measures to avoid inadvertently doing business with criminals or sanctioned individuals.

But, before we break down the AML high-risk industries list and provide actionable guidance on staying compliant, let’s look at the range of regulations at play.

The current AML regulatory landscape

In the UK, AML regulations are enforced through The Proceeds of Crime Act, The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 and the Economic Crime and Corporate Transparency Act 2023, which includes the new Failure to Commit Fraud offence, which came into force on 1^st September 2025.

Meanwhile, in Europe the 4^th, 5^th, and 6^th Anti Money Laundering Directives primarily oversee the enforcement of AML measures. Compliance with these obligations is monitored by a range of regulatory bodies and government agencies.

What places an industry at risk of money laundering?

As mentioned, FATF identifies specific risk factors that make certain sectors particularly vulnerable. This includes:

• High-value transactions that can disguise illicit funds
• Cash-intensive businesses where transaction trails are harder to follow
• International operations involving high-risk jurisdictions
• Complex ownership structures that obscure beneficial ownership
• Anonymity in transactions where buyers and sellers can remain unknown

Which industries are subject to AML obligations?

Financial services

• Banks and financial institutions sit at the heart of the financial system and therefore face the most comprehensive AML obligations. They must conduct enhanced due diligence on customers and monitor transactions for suspicious activity. This includes asset and fund managers, corporate finance, private equity firms, investment managers, and businesses that deal with crypto and digital currencies, such as Digital Currency Exchanges.

• Payment service providers connecting merchants, consumers, and financial institutions can pose a risk for money laundering by providing a means for individuals and entities to move illicit funds through the financial system. Therefore, robust AML procedures must be implemented, including identity verification, tracing the source of funds, and monitoring transactions.

• Fintech Companies such as buy now pay later, neo banks, and peer-to-peer lenders are increasingly vulnerable to criminals seeking to exploit the digital environment for the rapid movement of funds. A comprehensive AML programme is therefore a critical element of compliance and risk management.

• Insurance companies face money laundering risks posed by criminals using fraudulent or stolen identities to purchase insurance policies and pay premiums using illicit funds, or to place and conceal illicit funds by breaking them down into small premium payments. Meanwhile, organised criminals pose as ghost brokers to fake insurance documents, giving the impression that the buyer is insured, when in fact no policy exists, or take out a real policy on someone else’s, but cancel it shortly afterwards, keeping the refund.

• ‍‍Banks and financial institutions sit at the heart of the financial system and therefore face the most comprehensive AML obligations. They must conduct enhanced due diligence on customers and monitor transactions for suspicious activity. This includes asset and fund managers, corporate finance, private equity firms, investment managers, and businesses that deal with crypto and digital currencies, such as Digital Currency Exchanges.

• Payment service providers connecting merchants, consumers, and financial institutions can pose a risk for money laundering by providing a means for individuals and entities to move illicit funds through the financial system. Therefore, robust AML procedures must be implemented, including identity verification, tracing the source of funds, and monitoring transactions.

• Fintech Companies such as Buy Now Pay Later (BNPL), neo banks, and peer-to-peer lenders are increasingly vulnerable to criminals seeking to exploit the digital environment for the rapid movement of funds. A comprehensive AML programme is therefore a critical element of compliance and risk management.

• Insurance companies face money laundering risks posed by criminals using fraudulent or stolen identities to purchase insurance policies and pay premiums using illicit funds, or to place and conceal illicit funds by breaking them down into small premium payments. Meanwhile, organised criminals pose as ghost brokers to fake insurance documents, giving the impression that the buyer is insured, when in fact no policy exists, or take out a real policy on someone else’s, but cancel it shortly afterwards, keeping the refund.

Estate Agents

Estate and letting agents offer an ideal vehicle to convert illicit funds into legitimate assets. The sector faces unique challenges because transactions are infrequent but high-value, clients may be referred through complex chains of intermediaries, and properties can be held through corporate structures that obscure true ownership. They must therefore verify client identities, understand the source of funds, and report suspicious transactions.

Professional Services

• Solicitors and barristers often handle client funds through trust accounts, making them vulnerable to exploitation. They must apply a risk-based approach when onboarding clients and conducting transactions, with enhanced due diligence required for high-risk cases.

• Accountants and tax advisors can be unwitting facilitators of financial crime when they help structure businesses or manage accounts without proper oversight. AML obligations extend to auditors, external accountants, and tax consultants.

• Trust or company service providers create and manage corporate entities, trusts, and foundations, all structures that can hide beneficial ownership if proper controls aren't in place.

High-value goods dealers

• Art dealers and auction houses are notorious for criminality. With goods changing hands with minimal documentation, buyers can remain anonymous through intermediaries, whilst subjective valuations make it difficult to determine if an item has been intentionally overpriced to launder money.

• Precious metal and stone dealers, including jewellers who trade in gold, platinum, or diamonds, likewise conduct customer due diligence for high-value transactions.

• Luxury goods dealers for example, businesses selling high-end cars, yachts, or other prestige items, face similar risks and obligations when deals exceed sector regulatory thresholds.

Gambling and gaming operators

Casinos have long been recognised as money laundering hotspots. The ability to exchange cash for chips, gamble briefly, and cash out provides a perfect mechanism to disguise illicit funds. Meanwhile, a new breed of online operators face the additional challenge of remote customer verification and must implement robust identity and affordability checks without face-to-face interaction.

And the less obvious, or borderline cases:

• Charities and non-profits handling substantial donations
• Joint ventures with partners in high-risk jurisdictions
• Smaller providers crossing regulatory thresholds as they grow

Summarising the AML obligations for high-risk industries

Whilst risk exposures and regulatory requirements differ across sectors, and AML programs should therefore be designed to address the specific risks faced, it would be wise for all of the businesses mentioned above, including the borderline cases, to put in place AML processes, including:

Identity Verification (IDV)

Businesses must ensure that the individuals and entities they are dealing with are who they claim to be. For individuals, this typically involves the collection and verification of a variety of official documentation, biometric authentication, and database checks.

For entities, the process involves collecting and verifying a range of information and documentation, including company registration documents, business licenses, director information, proof of address, nature of business and ownership structure; as well as database searches for potential AML red flags such as sanctions and Politically Exposed Persons (PEPS) lists, and adverse media screening.  

Customer Due Diligence (CDD)

Businesses must next carry out Know Your Customer (KYC) or Know Your Business (KYB) checks to understand the nature of the customer’s business, potential risks they pose, and potential involvement in illegal activity.

This includes verifying customer identity, identifying and verifying beneficial owners, understanding ownership and control structures, accessing and obtaining information pursuant to the purpose and nature of the business relationship, and building risk profiles based on an understanding of the nature and purpose of anticipated transactions.

Enhanced Due Diligence (EDD)

For customers or transactions considered to be of high-risk, businesses should undertake enhanced due diligence (EDD) - a risk-based approach to investigation and the gathering of more detailed intelligence. EDD measures include adverse media screening, obtaining additional identifying information, analysing the source of funds, scrutinising Ultimate Beneficial Ownership (UBO) and transaction screening.

Ongoing monitoring

Customer behaviour changes and risk profiles evolve. An in-life customer monitoring approach, based on risk events and triggers for maintaining KYC checks and monitoring customers for the AML risks they pose. This involves monitoring and evaluating changes in customer profiles, business activities, ownership and organisation structures, legal status, as well as sanctions and PEPs watchlists screening, adverse media screening, payment and transaction monitoring.

Reporting and regulatory compliance

Businesses have a duty to report suspicious or nefarious activity uncovered during KYC processes. Organisations must submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) if they know, suspect, or have reasonable grounds for believing a customer is engaged in, or attempting, money laundering or terrorist financing.

How nCino Identity Solutions can help

Financial crime networks grow more sophisticated daily, whilst regulatory frameworks across EMEA continue to shift. High-risk industries must unify KYC, KYB, identity verification, sanctions, PEPs, and adverse media screening. Whether you're an estate agent, accountant, or art dealer, nCino Identity Solutions provides the AML screening tools your business needs to mitigate money laundering at every stage of the client lifecycle.

Ready to boost your AML resilience? Explore how nCino Identity Solutions can help you stay on top of compliance and spot risks sooner, while reducing manual efforts and costs, and improving the customer experience. Book your personalised demo today.