The UK’s National Crime Agency received 901,255 Suspicious Activity Reports in the year ending March 2024. That number has risen every year for over a decade, and it reflects something most people outside banking do not realise: money laundering is not a problem confined to financial services. It touches hospitality, estate agencies, legal firms, accountancy practices, and any business that handles significant cash or high-value transactions.
If your organisation falls within the regulated sector, your staff need anti-money laundering training. If they also deal with third parties, government contracts, or supply chains, they probably need anti-bribery and modern slavery training too.
What money laundering is
Money laundering is the process of making illegally obtained money appear legitimate. It typically follows three stages.
Placement is the first. This is where criminal cash enters the financial system, often through cash-intensive businesses like restaurants, car washes, or retail outlets. A hospitality business that takes large amounts of cash is a potential vehicle for placement, whether the owner knows it or not.
Layering comes next. The money is moved, split, converted, or mixed with legitimate funds to obscure its origin. This might involve transfers between accounts, purchases of property, or transactions across multiple jurisdictions.
Integration is the final stage. The laundered money re-enters the economy as apparently clean funds, used to buy property, invest in businesses, or fund a lifestyle. By this point, tracing the original criminal source is extremely difficult.
The legislation
Two pieces of legislation form the backbone of the UK’s anti-money laundering regime.
The Proceeds of Crime Act 2002 (POCA) created the legal framework for investigating and recovering criminal assets. Under POCA, it is an offence to conceal, disguise, convert, or transfer criminal property. It is also an offence to become involved in an arrangement that you know or suspect facilitates the acquisition, retention, use, or control of criminal property. Failing to report knowledge or suspicion of money laundering is itself a criminal offence.
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) set out the specific obligations for businesses in the regulated sector. These include conducting customer due diligence, maintaining records, appointing a Money Laundering Reporting Officer (MLRO), implementing internal controls and training programmes, and filing Suspicious Activity Reports (SARs) with the National Crime Agency.
Penalties under POCA include up to 14 years’ imprisonment for money laundering offences and up to five years for failing to disclose or “tipping off” a suspect.
Who needs AML training
Most people assume anti-money laundering rules apply only to banks. They do not. The MLR 2017 defines the regulated sector broadly: credit and financial institutions, estate agents, high-value dealers (any business that accepts cash payments of EUR 10,000 or more), accountants and tax advisers, independent legal professionals, trust or company service providers, letting agents, and art market participants dealing in works over EUR 10,000.
Hospitality businesses are not directly regulated under MLR 2017 in most cases, but they are far from immune. Cash-heavy operations like pubs, restaurants, and hotels are attractive to criminals at the placement stage. HM Revenue and Customs has investigated hospitality businesses for money laundering, and any business owner who suspects criminal activity has a duty to report it under POCA regardless of whether they fall within the regulated sector.
Our Anti-Money Laundering course covers the three stages, UK legislation, how to recognise suspicious activity, reporting obligations, the role of the MLRO, and the penalties for non-compliance. It takes one to two hours to complete.
The Bribery Act 2010
The UK’s Bribery Act 2010 is one of the strictest anti-corruption laws in the world. It creates four offences: offering or paying a bribe, requesting or receiving a bribe, bribing a foreign public official, and a corporate offence of failing to prevent bribery.
That last one is critical. Under Section 7, a commercial organisation can be prosecuted if a person associated with it (an employee, agent, or subsidiary) bribes another person to obtain or retain business. The only defence is proving that the organisation had “adequate procedures” in place to prevent bribery. Training is one of those procedures.
Penalties are severe. Individuals convicted of bribery face up to 10 years’ imprisonment and unlimited fines. Organisations face unlimited fines. The Serious Fraud Office has pursued cases against companies of all sizes.
What counts as bribery in practice? It goes beyond brown envelopes. Corporate hospitality can cross the line if the intent is to influence a business decision. A gift to a procurement contact before a tender submission is a red flag. Facilitation payments (small payments to speed up routine government processes) are illegal under the Act, even though they are tolerated in some other jurisdictions.
The Anti-Bribery and Corruption course covers the Bribery Act 2010, common scenarios involving gifts and hospitality, red flags, facilitation payments, and how to report concerns. It takes about an hour.
Modern Slavery Act 2015
The Home Office estimates that there are over 100,000 victims of modern slavery in the UK at any given time. The true figure is likely higher, because modern slavery is by definition hidden.
The Modern Slavery Act 2015 created specific offences for holding a person in slavery or servitude, requiring a person to perform forced or compulsory labour, and human trafficking. It also introduced the requirement for commercial organisations with a turnover of £36 million or more to publish an annual modern slavery statement outlining the steps they take to prevent slavery in their business and supply chains.
But the duty to report suspected modern slavery applies to everyone. If a manager, HR professional, or team leader recognises the signs of exploitation in their workforce or supply chain, they have a moral and legal responsibility to act. Signs include workers who appear fearful, are unable to speak freely, live in employer-provided accommodation with poor conditions, have their identity documents held by someone else, or show signs of physical abuse.
Hospitality is one of the sectors most affected. The Gangmasters and Labour Abuse Authority has investigated cases involving hotels, restaurants, car washes, and food processing plants across the UK.
The Modern Slavery and Human Trafficking course covers the Modern Slavery Act 2015, the types of exploitation, how to recognise the signs, the legal duty to report, and how to protect vulnerable workers. It takes one to two hours.
How these three areas connect
Money laundering, bribery, and modern slavery are not separate problems. They feed each other. The profits from forced labour are laundered through legitimate businesses. Bribery facilitates the corruption that allows trafficking networks to operate. A single criminal enterprise might involve all three.
For employers, this means compliance training should not be treated as isolated boxes to tick. Staff who understand one area will recognise patterns relevant to the others. A finance officer who spots unusual cash transactions might also notice signs that a supplier is using exploited labour. An HR professional aware of modern slavery indicators might also flag a suspicious payment arrangement.
Suspicious Activity Reports and the National Crime Agency
If any employee suspects that money laundering, bribery, or modern slavery is taking place, the correct response depends on the situation. For money laundering, the internal MLRO (or the individual directly, if there is no MLRO) must file a Suspicious Activity Report with the National Crime Agency’s UK Financial Intelligence Unit. Failing to file a SAR when you have knowledge or suspicion of money laundering is a criminal offence.
SARs are confidential. Tipping off the person suspected of money laundering (telling them that a report has been filed or that they are under suspicion) is also a criminal offence under POCA, carrying up to five years’ imprisonment.
For bribery, employees should use their organisation’s internal whistleblowing procedure. For modern slavery, reports can be made to the police, the Modern Slavery Helpline (08000 121 700), or the Gangmasters and Labour Abuse Authority.
How to get certified
Chefs Bay Academy offers all three courses: Anti-Money Laundering, Anti-Bribery and Corruption, and Modern Slavery and Human Trafficking. A licence costs £29 per learner, and that single licence gives access to all three courses plus 130+ others in the library.
Each course is CPD accredited, self-paced, and can be completed on any device. Learners work through the modules, pass an end-of-course assessment, and download their certificate immediately. The anti-money laundering course takes one to two hours, anti-bribery takes about an hour, and modern slavery takes one to two hours. A new starter could complete all three in a single day.
For a broader view of workplace compliance training, explore the full range of workplace courses in the library.
All these courses are included in your Chefs Bay Academy licence — £29 for instant access to 130+ courses.