ATT representation: Financial Services and Markets Bill 2026

The ATT has submitted a representation in relation to Clause 14 of the Financial Services and Markets Bill 2026.

The clause concerns the transfer of anti-money laundering (AML) and counter terrorist financing supervision from professional bodies and HMRC to the Financial Conduct Authority (FCA).

In our representation we note that, whilst we accept that supervisory reform is necessary, our preferred model would have been to strengthen the powers of the Office for Professional Body AML Supervision (OPBAS) rather than consolidating professional services AML supervision within the FCA. The vast majority of those we supervise are very small businesses that need guidance and help to get things right. It is unclear to us whether the FCA will provide them with proactive support of the kind and extent we do.

The legislation also leaves many questions unanswered. In our representastion, we call for early clarity on the proposals, including a realistic timeline for the transition, keeping burdens on the supervised population proportionate, and ensuring that education and bespoke support of the kind currently provided to our members remains available to them. Regulations should be published for consultation. 

We also note that non-compliance with AML requirements amongst our supervised population is focused on lack of paperwork and does not indicate that they or their clients are involved in money laundering. We receive little information from law enforcement about our members and despite frequent requests, we and our members receive very little granular feedback on the impact their suspicious activity reports make. We believe better feedback and wider publicity around successes could help AML regulated firms to see the value and importance of work in this area more clearly, keeping it at the forefront of their minds.