After two years of deliberation, the government has finally published its response to the 2023 consultation on reforming the UK’s anti-money laundering and counter-terrorism financing (AML/CTF) supervisory regime. The Financial Conduct Authority (FCA) has been crowned the Single Professional Services Supervisor (SPSS), a surprising outcome for many, not least the professions that will now fall under the FCA’s oversight.
The UK system currently comprises three statutory regulators—the FCA, HM Revenue & Customs (HMRC) and the Gambling Commission, alongside 22 Professional Body Supervisors (PBSs) overseeing the legal and accountancy sectors. Each PBS is responsible for ensuring that its supervised population complies with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs).
This structure has long attracted criticism. The 2015 national risk assessment (the UK’s first comprehensive assessment of money laundering and terrorist financing risk) first identified inconsistent supervision, while the 2018 FATF (Financial Action Task
