A. The government previously issued a consultation about reforming anti-money laundering and terrorist financing supervision in 2023.  The ATT responded to this consultation and the response is available on the website.

Four possible options were considered:

• OPBAS+ - retaining the current supervisory regime but with enhanced powers for OPBAS

• Professional Body Consolidation – consolidating supervision into one accountancy supervisory body and one or two legal bodies

• Single Professional Services Supervisor (SPSS) – move all professional body supervision (and possibly HMRC) into one supervisor

• Single AML supervisor (SAS) – move all AML supervision into one body (to include professional body supervision, HMRC, Gambling Commission and FCA)

Our response indicated our support for OPBAS+. Our key points being that other options risked a decrease in supervisory effectiveness in the short to medium term whilst arrangements transitioned.  There may well be a loss of AML expertise as many staff would not move across to other bodies and new staff would need to be recruited and trained.  As OPBAS had been in place for less than 6 years and given the improvements already implemented we felt that more time was needed to see their work come to fruition.  We also considered that AML supervision should be considered alongside regulation of the tax profession.

A. HM Treasury issued their response to the consultation on 21 October 2025.  The decision has been made to move entities currently supervised in relation to accountancy services and trust and company service provider work by the professional bodies and by HMRC to the Financial Conduct Authority (FCA).  Entities supervised in relation to legal services will also move across to be supervised by the FCA.

The government consider that the current regime is complex and disjointed.  In March the government committed to simplify and improve regulation in the UK.  The proposed changes are viewed as simplifying the current regulatory system and strengthening the UK’s defences against financial crime.

A more detailed rationale is set out in sections 2.14 to 2.19 of the consultation response as follows:

• The government believes a public organisation overseeing professional services firms is the most effective approach to supervision.  Firms will be integrated into the FCA’s framework and bring these firms in line with other sectors the FCA supervise.
• The FCA will have a large remit and be able to rake a risk based approach across 60,000 regulated firms.  Lower risk firms will receive attention according to their risk profile.  The government see this as aligning with the government’s wider work to ensure regulators act proportionately.
• HM Treasury’s intention is for the FCA to build specific expertise in the sectors it supervises.
• The FCA will have the powers to take strong dissuasive enforcement action.
• A public sector authority will be more easily able to facilitate information sharing with law enforcement.

The change will support other reforms such as Companies House reform.

A. No timeline for the changes is set out in the consultation response.  There will be a further consultation which will be issued in early November 2025 which will seek views on the powers that the supervisor should have.  Implementation of the policy is subject to all of the following:

• Enabling legislation and parliamentary time available
• Confirmation of funding arrangements
• A detailed transition and delivery plan

We will ensure this website page is updated as matters develop and will ask for your feedback where required.

A. As far as the ATT are concerned it is very much business as usual at the moment.  We will continue to conduct AML supervisory reviews and work with members to provide guidance and help them to comply with the requirements of the Money Laundering Regulations.  Members who do not comply will continue to be subject to referral to the Taxation Disciplinary Board so it is important that supervised firms maintain levels of compliance throughout.

ATT will aim to work constructively with HM Treasury and the FCA over the coming period, and will continue to work collaboratively with the aim of:

• Agreement of timelines as a priority to give certainty to AML supervised firms and internal supervisory teams. It is important that firms do not experience long periods of uncertainty and that the transitional period does not cause firms to be distracted from their obligations under the Money Laundering Regulations while they focus on the move to a new supervisor.
• Seeking to ensure administrative burdens for firms are proportionate and working to avoid the duplication of burdens where there are multiple supervisors.
• Feeding back on proposed fee structures for supervision to ensure the costs of providing tax advice are not increased.  Increased costs may mean clients cannot afford the services of tax advisers or advisers may seek to retire to reduce their costs.  Less cost effective tax advice in the market may mean members of the public cannot access tax advice which may result in increases in the tax gap.
• Maintaining expertise on the supervision of tax advisers and ensuring new arrangements recognise the features of tax practices which supervisors need to be aware of and the AML risks faced.
• A smooth transition of information and supervision work to the FCA to avoid a reduction in supervisory effectiveness. Funding of supervision during the transitional period will be an important factor here to ensure the transitional period is effective.
• Working with the FCA to ensure there is an adequate programme of education for supervised firms so they understand the implications of the transitional period and the move of supervisors.

A. In the first instance please email [email protected] but we also recommend regular review of this webpage.