By AAT Comment Anti-money laundering AAT Disciplinary, Professional Standards and Regulation update 1 Oct 2025 New version of Indicative Sanctions Guidance for members to aware of. AAT recently published a new Indicative Sanctions Guidance document (PDF). The guidance outlines how sanctions will be determined in disciplinary cases involving our members and is used by AAT’s Investigations Team, Disciplinary Tribunal Committee and Appeal Committee when considering disciplinary matters. It was presented to the Professional Standards and Regulation Board (PRSC) for final approval at their meeting in September 2025. The changes The proposed changes are a result of a review of the existing guidance where stakeholder insight suggested clarity was required. These amendments are also intended to ensure alignment with the evolving regulatory expectations placed on AAT as a Professional Body Supervisor, thereby enabling us to fulfil our enforcement duties under Regulation 49(1)(d) of the Money Laundering Regulations 2017. This is achieved by AAT ensuring that any contravention of a relevant AML requirement, the member be liable to effective, proportionate and dissuasive disciplinary measures. Furthermore, these changes aim to support public confidence and to maintain a dissuasive, proportional, and fair application of our disciplinary measures. This is an opportunity for all members to read the guidance in full and familiarise themselves with our compliance requirements. If you have any questions, or have an open disciplinary case that you would like to discuss, please contact the Investigations and Disciplinary team at [email protected]. Recommended reading AAT sanctions for AML breaches PII: avoiding non-compliance sanctions and penalties Future of supervision On 21 October 2025, the Government confirmed that the AML supervision for accountancy, legal and Trust and Company Service Provider sectors will move to a single professional services supervisor (SPSS), specifically the Financial Conduct Authority. While this is a big shift, implementation is likely to take years. In the meantime, AAT will continue as the AML supervisor for our licensed members and carry out our normal responsibilities, including Practice Assurance Reviews and risk assessment activities. Therefore, our members must ensure full compliance with the MLR 2017. More on the consultation response can be found here. Further guidance and support on risk management and other components of Money Laundering Regulations compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email at [email protected]. AAT Comment offers news and opinion on the world of business and finance from the Association of Accounting Technicians.