The FCA has repeatedly stated its intention to use the full range of its available tools, including its criminal and investigation powers under the Money Laundering Regulations (MLRs), to combat money laundering.

Despite such rhetoric, we are yet to see any evidence of criminal investigations being used as more than tactical leverage in investigations.

Indeed, as reported today, the FCA has shut down seven - or half - of its criminal AML investigations since the beginning of the year. The remaining seven investigations are principally dual-track, meaning they may well result in only civil outcomes.

Nevertheless, AML enforcement remains a priority as set out in the FCA's Annual Report: "Our aim is to minimise the incidence of money laundering and terrorist financing."

It will be interesting to see whether the FCA chooses to take criminal action in any of the remaining AML investigations that it has open.