2 The UK AML regime
2.1 Background
The AML provisions applicable in the UK flow from the overarching framework recommended by FATF and legislated for via a series of EU Directives culminating in the transposition of 4MLD (with its amending directive, 5MLD, yet to be transposed at the time of writing).1 These overarching provisions form the cornerstone of UK AML measures and both inform and shape the UK legislative framework. The AML regime in the UK is underpinned by a trinity of statute, regulations and sector-specific guidance, which can be conceived of conceptually as forming two pillars: those of prevention and enforcement.2
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