The £3,000 DAML Shift - Why You Can’t Afford to Get It Wrong

As of 31 July 2025, the UK raised the threshold for Defence Against Money Laundering (DAML) requests from £1,000 to £3,000.

It was expected. It makes operational sense. But it’s already being misunderstood.

Across Fin services, accountancy firms, legal practices, and estate agencies, conversations around this update it is clear that one assumption is spreading fast, “If it’s under £3,000, we don’t need to report it.”

That’s not just wrong, it’s very dangerous.

The new threshold changes one thing and one thing only, when you need to pause and get consent from the NCA before proceeding with a transaction.

It does not remove your legal duty to file a Suspicious Activity Report (SAR).

It does not change your obligation Section 330 of POCA.

And it certainly doesn’t mean low value transactions are now off the radar.

If you suspect criminal property, even if it’s just £500, the obligation to report still stands. You don’t get to opt out because it’s below £3K.

There’s no “too small to matter” clause in AML legislation.

And yet, that’s exactly what some professionals are now assuming that all this means is less admin, fewer DAMLs and more time to focus on business.

Whats the big risk you may think.

If you are a Solicitor, Accountant or Estate Agent handling a £2,750 payment from a client in a high risk country and suspect red flags on source of funds, you might not need a DAML anymore, but if you don’t file a SAR and it turns out to be dirty money, the liability’s yours.

We’re not dealing with a compliance change. We’re dealing with a mindset shift and that discretion is now a liability if you’re not careful.

Because if something goes wrong, and there’s no SAR, you can’t say “but it wasn’t £3K.” That’s not a defence. That’s a misunderstanding of the law. And as we all know, ignorance is not a defence.

The goal of the threshold change was efficiency, not leniency. Less paperwork for the NCA. More focus on serious crime. But that doesn’t mean the small stuff has gone away. In fact, the small stuff is often the first clue.

Now is the time to retrain staff.

Revisit AML procedures.

Tighten internal escalations.

And most importantly, document everything! Especially the decisions not to file.

To strengthen your personal and commercial defences with tailored solutions, I welcome the opportunity to connect.

JOA Solutions

Clarity. Compliance. Confidence.