Many firms subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLRs”) are shortly to be subject to a new levy: the Economic Crime (Anti-Money Laundering) Levy (“ECL”).  This new levy was announced in the government’s 2020 budget to help fund new government action to tackle money laundering and to ensure delivery of reforms committed to in the 2019 Economic Crime Plan.

Consultation on the levy closed in October 2020 and the response to the consultation was published in September 2021.  The implementing provisions are contained in the Finance Act 2022 and the Economic Crime (Anti-Money Laundering) Regulations 2022. They come into effect from 1 April 2022 for the government financial year 1 April 2022 to 31 March 2023 and are payable after that year ends.

In-scope entities.  An entity is in scope if they are AML regulated and have carried out regulated activity under the MLRs at any point in the levy year (but it will be applied pro rata).  This includes:

  • Credit institutions and financial institutions
  • Auditors and others
  • Independent legal professionals and trust or company service providers
  • Estate agents and letting agents
  • High value dealers, casinos, auction platforms and art market participants
  • Cryptoasset exchange providers and custodian wallet providers

Charging basis.  The gambling sector expressed its preference for the levy to be based on gross gambling yield, and land-based casinos were concerned that when compared to online casinos they were at risk of disproportionate treatment due to existing higher tax commitments and more acute Covid 19 impacts.  Other sectors wanted the levy charge added into existing AML supervisory fees.  However there are no sector specific treatments in the levy.  It will apply based on UK revenue as determined by UK GAAP.  Non-UK resident casinos, regulated by the Gambling Commission, which provide facilities for remote gambling but have no permanent establishment in the UK will also be subject to the ECL.

Amount.  Levy amounts will be based on four size bands based on UK revenue: small, medium, large and very large.  The levy will be a fixed fee which should not equate to more than 0.1% of UK revenue.  Small entities (all regulated entities with UK revenue below £10.2 million) will be exempt form the levy (and will not be required to report any information).

Collection agency.  The levy will be collected by the three statutory AML supervisors: HMRC, FCA and the Gambling Commission, rather than all 25 AML supervisors.  HMRC will take on collection responsibilities for in-scope legal and accountancy firms supervised by the 22 professional body supervisors.  For entities jointly supervised by the FCA and the Gambling Commission, the FCA will be responsible for collecting the ECL unless the FCA and Gambling Commission agree otherwise.

Overview of annual charge:

Size of firm

UK revenue threshold

Levy amount


£10.2m ≤ £36m



£36m ≤ £1bn


Very large

> £1bn


Overview of return information:

Supervisory authority


Content of return


May return info be made public?

Payment of levy


Entity obligation to make return

As specified in a notice published by HMRC


Not stated

30 September after end of FY to which liability relates.

Gambling Commission

Entity obligation to notify liability and make return

As specified in a notice published by Gambling Commission



30 September after end of FY to which liability relates.


FCA will notify entities required to make return

As specified by FCA in notice


Not stated

By date notified, not less than 30 days after notification