National Risk Register 2026: Why Cyber Resilience Is Now an AML Issue

The Compliance Function Is Expanding

For many years, AML teams focused on traditional financial crime risks.

Identity verification.

Source of Funds.

Beneficial ownership checks.

Sanctions screening.

Today, that landscape is changing.

According to the National Risk Register, cyber threats remain among the most significant risks facing the UK. While many organisations view cybersecurity as an IT issue, law firms should increasingly consider it a compliance issue too.

The links between cybercrime and financial crime are becoming impossible to ignore.

The New Criminal Economy

Modern organised crime groups are highly sophisticated businesses.

They use:

• Stolen digital identities
• AI-generated documentation
• Account takeover attacks
• Ransomware
• Synthetic identities
• Dark web marketplaces

These tools enable criminals to move money, establish fraudulent businesses and conceal beneficial ownership more effectively than ever before.

The result is that cybercrime increasingly acts as an entry point into money laundering and other forms of financial crime.

Why Law Firms Are High-Value Targets

Law firms sit at the centre of some of the UK's highest-value transactions.

Whether handling property purchases, corporate investments or trust structures, firms deal with significant sums of money and sensitive client information.

This makes them attractive targets for organised criminals.

The National Risk Register reinforces the growing importance of resilience against sophisticated and evolving threats.

For law firms, the question is no longer:

"Could we experience cybercrime?"

It is:

"How would cybercrime affect our ability to meet our AML obligations?"

A Compliance Challenge Hidden in Plain Sight

Many compliance frameworks still treat AML and cybersecurity as separate disciplines.

Increasingly, that is becoming a mistake.

Consider the following scenarios:

• A stolen identity used during onboarding.
• A compromised client account used for payment diversion.
• AI-generated documentation submitted as Source of Funds evidence.
• Criminals using synthetic identities to conceal beneficial ownership.

Each begins with a cyber-enabled attack but quickly becomes an AML problem.

The Technology Gap

Our research found that only 45% of legal firms have adopted digital verification, while 55% still rely predominantly on manual processes.

At the same time:

• 72% expect regulatory complexity to increase.
• 49% describe regulations as very or extremely complex.
• Only 23% are highly confident in their obligations.  

These findings suggest many firms are already under pressure without the added complexity of AI-driven fraud and cyber-enabled crime.

Building Resilience

Future-ready firms should consider:

• Digital identity verification
• Ongoing monitoring
• Automated sanctions screening
• Stronger Source of Funds verification
• Enhanced beneficial ownership controls
• Better staff awareness training

Cyber resilience is no longer solely an IT objective.

It is increasingly a compliance requirement.