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UK National Risk Assessment 2025 - Movers, Shakers, and Surprise Entrants

The long-awaited UK National Risk Assessment (NRA) 2025 has arrived, providing a fresh perspective on money laundering (ML) and terrorist financing (TF) risks across key sectors.

Key Sector Changes

Sector Movement Points to Note
Electronic Money and Payment Firms   ML/TF ↑  These firms are now classified as high risk for both money laundering (ML) and terrorist financing (TF). This sharp increase places fast-moving fintech companies under significant regulatory scrutiny. 
Crypto-Asset Businesses          ML    ↑  The risk level for money laundering in this sector has been elevated to high, a crucial change driven by real-world criminal activity and delays in global regulation. 
Wealth Management          TF     ↑  The risk of terrorist financing has been upgraded to medium, reflecting rising concerns about offshore trusts and the exposure of international clients. 
Trust and Company Service Providers (TCSPs)          TF       ↑  The threat level for terrorist financing is on the rise, as complex structures are increasingly identified as tools for obscuring financial flows. 
Casino Sector        ML     ↑  The trend for money laundering risk is increasing, driven by online gambling and cryptocurrency, which facilitate anonymous and rapid value transfers. 
Insurance Sector   New sector assessed  This sector has entered the NRA as a standalone category for the first time. Although it is rated as low risk, its inclusion indicates a widening focus of regulatory oversight. 
Letting Agents and Art Market Participants        ML       ↓ 

The risk levels in these areas are trending downwards, thanks to improved supervision, increased awareness, and better registration practices.

 


How Thistle Initiatives Can Help

Assurance

  • Conduct a Financial Crime Audit assessing the design and operational effectiveness of your firms controls in light of changes to the NRA.

Advisory

  • Conduct your business wide risk assessment and ensure that any changes to risks, are properly evaluated and mitigated.
  • Review the end-to-end effectiveness of controls across onboarding, transaction monitoring, and crypto asset transfer and provide workable recommendations for enhancements.

Managed Services

  • Mobilise experienced expert resource to support enhancements to your framework due to the change in risk profiles.

Meet the Expert

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Eva Koreskova, Senior Consultant  LinkedIn

Eva is a Senior Financial Crime Senior Consultant, bringing over seven years' experience in financial crime management, regulatory compliance, and risk assessment. Previously, she led financial crime initiatives at an asset financing firm, where she presented insights to senior leadership and implemented robust control measures across the firm. Eva’s background includes roles at a bank and a brokerage firm, where she drove compliance initiatives, managed high-risk clients, and advanced financial crime systems and controls. As an ICA-certified MLRO, Eva is dedicated to safeguarding organisations against financial crime through strategic compliance frameworks and industry best practices.