What AML/CTF supervision reform will mean for AAT members

Supervision is moving from membership bodies, like AAT, to the FCA. What impact will this have?

The sector is facing its biggest regulatory shift in years. In 2025, the government decided to move anti-money laundering (AML)/counter terrorism financing (CTF) supervision for accountancy and legal services to the Financial Conduct Authority (FCA).

Right now, many practical details are still being developed, for example, what the FCA fees might look like. With a transition team now in place, the FCA has begun intensive engagement with the Professional Body Supervisors at various levels, and AAT is actively involved in this process.

AML supervision is one aspect of the service AAT provides to members. Not all members are licensed for these purposes by us, and we do plenty of other work for you too. That includes influencing policymakers and advocating for your needs, keeping you up-to-date on legislative changes, and so much more.

We’ll continue to support the profession through this period of change, and to make sure your voice is represented as the new system takes shape. We’re in the process of regularly meeting officials on the planned implementation programme, and ways of collaborating.

What does this mean for AAT AML supervised members?

 In the meantime, the message to members we supervise for the purpose of the AML compliance is continue as normal. Your AML obligations remain exactly the same today as they were last year, and all current supervisory arrangements remain in place for now.  For example, you must ensure you continue to comply with the Money Laundering Regulations; you must complete the annual AML firm return and submit to a Practice Assurance Review.

This is still only the early days of a multi-year journey towards a new AML regime. 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].

What about other members?

AML/CTF supervisory regime reform won’t result in any regulatory changes for you.

Being a voice for members

AAT has been an AML supervisor for many years, and that experience puts us in a strong position to influence the new regime. Even when our formal supervisory role eventually comes to an end, our commitment to supporting all our members absolutely won’t. 

In fact, this shift opens the door for us to rethink how we help firms stay compliant, confident, and well prepared. We’re already looking at how our guidance, resources, and policy work can evolve to reflect this. 

Our aim is to make this change as smooth as possible. With the direction now set, we’re focused on delivering a robust supervisory system that upholds the highest standards for our profession.  

What’s happened so far

HM Treasury focused its 2025 consultation response on the key duties, powers, and accountability mechanisms that the FCA will need to be an effective supervisor. You can find our published response here. We’re currently awaiting a response.

HM Treasury also ran a series of workshops, which we used to highlight the need for a clear transition plan that is proportionate and transparent, considering the diverse set of businesses reform will impact.  

Our message to the FCA

We support the government’s objective for stronger, more consistent oversight. However, the move to the FCA needs to be carefully managed to avoid disruption. We’ve stressed that any transition should prevent duplication, gaps in oversight, and unnecessary demands for information. Good planning, clear communication and proper resourcing are essential.  

AAT represents a diverse range of financial professionals, from experts in small practices to those working in large accountancy firms, industry and beyond. We believe key proposals such as public register, fit-and-proper tests, better information-sharing, and stronger enforcement are all required. However, supervision must be balanced.

Firms across the profession operate very differently, and they face different levels of risk. We have been clear about the need for a proportionate, risk-based approach which reflects the realities of smaller practices as well as larger firms. A single, uniform model simply won’t work. 

Stronger enforcement has a role to play, but it must be fair and proportionate. We’ve recommended an approach that supports firms to remedy issues first, escalating only where there is serious or repeated noncompliance. Education and guidance should always come before punishment. 

Many small practices are already facing rising costs. If regulation becomes too costly or complex, some may leave the market, and that could reduce access to essential services for hundreds of thousands of small businesses. In other words, the cost of regulation must be affordable.

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