HMT announces major overhaul of anti-money laundering supervision

AAT’s reaction to the Government’s announcement, and what’s coming next for members.

HM Treasury ran its consultation on strengthening anti money laundering (AML) and counter terrorist financing (CTF) supervision for legal and accountancy firms in 2023. AAT published a response to the AML supervisory reform consultation on 29 September of that year. 

In our view, Model 1 (OPBAS+) would result in a demonstrable improvement to the sector, so was the most suitable option. We and 12 other Professional Body Supervisors (PBSs) therefore wrote to Treasury Lords Minister Baroness Penn, urging her to consider feedback contained within the letter and support Model 1.

The 21 October 2025 announcement

Of the four options put forward, the Government confirmed that it’ll move to a single professional services supervisor (Option 3), specifically the FCA.

In practice it means the FCA will supervise:

• all firms (including sole practitioners) currently supervised for AML/CTF by legal and accountancy professional body supervisors
• and all accountancy service providers and trust and company service providers (TCSPs) supervised by HMRC.

Once this happens, the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) will be wound up.

What’s the future for AAT members?

AAT supervises over 7,000 of our licensed members for AML compliance. In time, this will move to the FCA.

However, we’ll keep responsibility for upholding professional standards and helping our members meet their regulatory obligations. AAT expects high standards of competence and professional conduct from all our members. Every AAT member must adhere to our Code of Professional Ethics.  

While this is a big shift, implementation is likely to take years. The Government will need to overcome hurdles such as further consultation on the FCA’s powers (planned for November 2025), transition planning, primary legislation and funding agreements.

In the meantime, we’ll continue as the AML supervisor for our licensed members and carry out our normal responsibilities. These include risk assessments, member guidance, training, and engagement with OPBAS and other stakeholders. This does not change firms’ (including sole practitioners) obligations under the MLRs, as mentioned in the consultation response.

While reform presents challenges, it also presents us with real opportunities. As one of the largest professional body supervisors, we’ll have the chance to shape the future regime, including which powers the FCA will require to carry out their duties. Our role influencing AML policy will remain for years to come, ensuring reforms are effective and proportionate. 

We’ll also redouble our efforts on providing high-quality guidance, improving professional standards, and advocating for our members. We’re already looking at ways to enhance our member offer.

AAT’s reaction 

AAT continues to examine the consultation response and will follow up with further comms. Please see our media response:

“AAT acknowledges the Government’s decision to transfer AML supervision for anti money laundering (AML) and counter terrorist financing (CTF) supervision to the FCA. Whilst this change won’t happen overnight, it will be a significant shift for the accountancy sector offering a clear path forward. We remain committed to supporting our licensed members with the expert guidance, resources, and reassurance they need to stay prepared and compliant throughout this transition and beyond. 

“While there will be challenges ahead, such as ensuring a seamless data transfer and maintaining specialised support, AAT is focused on making this change as smooth as possible. With the direction now set, we’ll work closely with the Government and stakeholders to ensure an effective transition, delivering a robust supervisory system that upholds the highest standards for our profession.”

Next steps 

AAT has always been more than a supervisor. We’re dedicated to providing our members with the support they need, and we’re working hard to improve our licensed member offer, including continuing to offer support with AML, even if we’re no longer the supervisor responsible for supervision and enforcement.   

We’ll be contacting our members throughout the transition, making sure they stay up to date on next steps and timeframes, and we’ll also work closely with the Government and others to help the transition, and final outcome work in practice.   

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].

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