Reform of the Anti-Money Laundering and Counter-Terrorism Financing Supervision Regime
In 2023, HM Treasury (HMT) published consultation on reforming the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) supervisory framework.
After reviewing the consultation responses and supporting evidence, the Government decided to proceed with Option 3: the creation of a Single Professional Services Supervisor (SPSS). Under this model, the Financial Conduct Authority (FCA) will undertake responsibility for supervising legal, accountancy and trust or company service providers for AML/CTF purposes. A copy of the Consultation Response can be read here.
The Consultation Response explains that the FCA will supervise firms that carry out activities within scope of the Money Laundering Regulations (MLRs) as Legal Service Providers (LSPs), Accountancy Service Providers (ASPs), and Trust and Company Service Providers (TCSPs). In practice, this means that all firms currently supervised for AML/ CTF purposes by a PBS, and all ASPs and TCSPs supervised by HMRC will be supervised instead by the FCA.
The implementation timeline will depend on the passage of primary legislation, but planning is already underway with the FCA. In the interim, HM Treasury has issued a further consultation seeking views on the powers, duties, and accountability mechanisms the FCA will need to be an effective supervisor. This consultation sets out proposals for a more streamlined and strong supervisory framework. You can access the consultation document here
Notaries are encouraged to attend a series of roundtables hosted HM Treasury. These roundtables are an opportunity for meaningful discussion on the proposals set out in the consultation.
Below are the dates and links for the following sessions:
Accountancy & TCSPs:
Legal Sector: