AML Supervision changes planned

Major changes are planned to the AML supervision arrangements for accountants, bookkeepers, tax advisers, auditors, insolvency practitioners and trust or company service providers (TCSPs), and lawyers who are subject to the UK Money Laundering Regulations 2017. Essentially, the existing arrangements for AML supervision by 22 private sector professional bodies and HMRC are to be swept away. Instead AML supervision will be provided by the Financial Conduct Authority (FCA) whose remit is to be extended to cover these practitioners.

The FCA currently provides AML supervision for financial institutions such as banks.

The plan

The plan was announced by the UK Government in its response to a consultation on the AML supervision of professional firms which was opened as long ago as Summer 2023 (under a previous government). On 21 October 2025 the government announced its decision to create a Single Professional Services Supervisor (SPSS) within the FCA. The new SPSS will take on the anti-money laundering (AML) and counter-terrorist financing (CTF) supervision role currently performed by the 22 private sector professional bodies and HMRC – who will then have no role in AML supervision. However the private sector accountancy bodies, the largest of which are ICAEW and ACCA, will continue to regulate their members for other purposes.

In consequence OPBAS – the Office for Professional Body Anti-money laundering Supervision – will no longer have a role, and will cease to exist.

It is expected that the FCA will need to supervise approximately 60,000 additional entities as a result of these changes.

Putting the plan into action

The FCA is a body created by statute, whose powers and duties are set out in statute. In order to extend the remit of the FCA, and give it the powers it will need, a new Act of Parliament will be required. As a first step the government intends, this month, to issue a new consultation document on the proposed new powers and duties of the FCA.

After that consultation, a new Bill will be introduced into the Westminster Parliament. Once that Bill passes and becomes an Act it is likely to be implemented by Statutory Instruments. It will also be necessary to further amend the Money Laundering Regulations 2017 (which currently refer to supervision by the 22 professional bodies and HMRC).

The current AML Guidance for the Accountancy Sector is issued by the Consultative Committee of Accountancy Bodies (CCAB). That will need to be replaced by new guidance to be drawn up by the FCA.

When will this happen?

In view of the steps needed before supervision by the FCA can take effect, the change will not happen quickly. The change is unlikely to take effect before 2027, and some commentators have suggested that it may be as late as 2029.

How will this affect accountants?

The impact on accountants will become clearer in due course, particularly when the necessary Act of Parliament has been passed and the new AML Guidance for Accountants has been published by the FCA. This change in AML supervision arrangements does not, of itself, necessitate any changes to the obligations of accountancy firms in relation to the identification of clients, the need for client and firm-wide AML risk assessments, AML policies, controls and procedures documents, staff training, and so on.

The government has made clear that, once the new arrangements are in operation, the day to day running costs of the AML supervision by the FCA are expected to be met by fees which will be payable by supervised firms.

It is possible that guidance prepared by the FCA will be more voluminous and more prescriptive than the current CCAB guidance. It is also possible that financial penalties for non-compliance may be more severe.

Some commentators have expressed a concern that the FCA will not have a good understanding of the operations of small firms in the accountancy sector and the AML risks such firms face. It does appear to be the case that the government finds it hard to understand why the professional firms submit relatively few Suspicious Activity Reports (SARs) to the National Crime Agency as compared to the hundreds of thousands of SARs submitted annually by banks.

If you are concerned that your firm’s AML compliance is inadequate, or even non-existent, get in touch now using the link below and we can work together to fix this. The hardest part is getting started.

David Winch

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