The UK is gearing up for one of the most significant expansions of its anti-money laundering (AML) regime in years. From mid-2026, charities, universities, and football agents will formally fall within the scope of AML regulation bringing mandatory due diligence, stricter oversight and new accountability requirements to sectors historically treated as low risk.

The move signals the government’s determination to close long-standing loopholes exploited by criminals, strengthen national financial integrity and align the UK more closely with global AML expectations set by FATF.

But the implications reach far beyond the regulated entities themselves. Law firms advising these sectors will need to reassess their own risk frameworks, onboarding practices and due diligence expectations.

Why these sectors? Why now?

The Treasury and UK regulators have been increasingly vocal about vulnerabilities in sectors that handle large and often international financial flows but have had inconsistent AML oversight.

Charities frequently operate internationally, rely on diverse donor funding, and often receive high-value donations. Universities take in billions annually through foreign student tuition, research funding, and philanthropic gifts. Football agents manage high-value transfers and player contract negotiations, areas ripe for exploitation by bad actors.

A treasury spokesperson noted, “These sectors have been identified as having exposure to illicit finance… we aim to close loopholes exploited by money launderers.” 

The decision aligns with a global trend of countries pushing AML controls into previously under-regulated sectors where criminals have found opportunity.

What the new AML requirements look like

While detailed secondary legislation is expected, it appears that the following obligations will become mandatory:

For charities

• Mandatory CDD on all donors, especially large or international contributions 
• Beneficiary checks for higher-risk programmes 
• Enhanced record-keeping and audit trails 
• Risk assessments for operations in conflict zones or high-risk countries 
• Supervision by the Charity Commission 

This represents a significant uplift. Many charities currently rely on voluntary or light-touch processes. Under the new rules, AML controls become a core regulatory requirement.

For universities

• Customer Due Diligence (CDD) on students and donors 
• Verification of source of funds, especially from overseas 
• Appointment of a Money Laundering Reporting Officer (MLRO) 
• Mandatory staff training and internal controls 
• Suspicious Activity Reports (SARs) to the NCA 
• Supervision via the Department for Education under the new AML framework 

The shift is big. Universities, especially those with large international student populations, will need to overhaul payment pathways, onboarding and donor management.

For football agents

• Enhanced transparency rules on fees and transfers 
• CDD on clients and counterparties 
• Reporting of large or unusual transactions 
• Supervision by the FCA 

Given the scale of football finances, often moving millions in short windows, this is one of the highest-impact changes.

What this means for law firms

This is where the impact becomes two-fold.

Clients will need guidance 

Law firms working with charities, education institutions, sports professionals, or football intermediaries will be expected to:

• Advise on AML risk assessments 
• Set up MLRO and reporting frameworks 
• Draft or update AML policies 
• Support onboarding, donor/student verification processes 
• Prepare clients for FCA / Charity Commission / DfE supervision 
• Handle regulatory challenges or investigations 
• Provide training or internal workshops 

Clients will look to their advisers for clarity, particularly those who have never been inside the AML regulatory perimeter before.

Your own AML approach may need to change

Many law firms apply simplified due diligence to charities or education clients, assuming they pose lower AML risk. Under the new regime, that assumption may no longer be defensible.

Firms will need to re-evaluate:

• Client risk ratings (charities and universities may shift into “medium” or “high” categories depending on international exposure) 
• Source of Funds checks for payments from students, donors, international programmes or high-value transfers 
• Ongoing monitoring of clients in these newly regulated sectors 
• EDD triggers, especially for football-related transactions 
• Reliance decisions. Can you still rely on CDD conducted by a university or charity? 

If your firm acts for large charities, global universities, or high-profile football agents, the changes may significantly alter your onboarding processes.

A more transparent UK financial system

From a policy standpoint, this expansion reflects a clear desire to protect the UK’s international reputation and demonstrate stronger alignment with FATF and other global AML standards. It signals a deliberate push to close gaps in sectors historically viewed as “soft targets,” creating greater regulatory consistency across industries that handle significant financial flows. More broadly, it marks a shift toward a genuinely risk-based, holistic AML regime, one in which all financially active organisations, not only banks and professional services, are expected to carry defined responsibilities in safeguarding the system from illicit finance.

The new AML rules will likely formally enter into force in mid-2026. Organisations will have a long runway to prepare, but the scale of change should not be underestimated.

A wake-up call?

This expansion is a fundamental shift in the UK’s AML landscape. For charities and universities, it formalises responsibilities that many have never had to manage. For football agents, it brings them into line with other high-value financial intermediaries. For law firms, it requires a fresh look at client risk, advice frameworks, and due diligence practices.

As the UK tightens the net on illicit finance, all organisations, especially those newly brought into scope,  will need to adopt more robust AML cultures. And law firms will play a central role in getting them there.

Training your staff in AML needs to be more than a tick-box exercise. Companies and law firms can easily fall out of compliance or get caught up in dirty money without a robust AML framework. Try our online training courses here.