The FCA is replacing 23 professional body supervisors as the single AML supervisor for around 60,000 UK law firms, accountancy practices and trust and company service providers. The transition runs through 2027 and 2028. Most small firms are not yet ready. We help them prepare.
In October 2025, HM Treasury confirmed that the Financial Conduct Authority will become the Single Professional Services Supervisor (SPSS) for anti-money laundering and counter-terrorist financing. This consolidates AML supervision currently carried out by 23 separate professional body supervisors, including the SRA, ICAEW, ACCA, ICAS, the Law Society, IPA, CILEx and CIOT, into a single statutory supervisor.
Around 60,000 firms are in scope: UK legal service providers, accountancy service providers, and trust and company service providers. Firms already supervised by the FCA under FSMA remain so. HMRC will continue to supervise estate and letting agents, high-value dealers and money service businesses.
Government decision announced. HM Treasury confirms the FCA will become the Single Professional Services Supervisor (SPSS) for anti-money laundering and counter-terrorist financing.
HM Treasury consultation on the FCA's expanded powers closes.
King's Speech expected to announce the AML Supervision Bill.
Draft legislation setting out the FCA's expanded remit.
Bill expected to receive Royal Assent.
Transition phase. Firms register with the FCA, fit-and-proper assessments begin, and a new AML Handbook is published.
Full implementation across all in-scope firms.
HM Treasury's 2024 to 2025 supervision report found only 24% of accountancy firms and 29% of legal firms fully compliant with the Money Laundering Regulations. Among the highest-risk legal firms, 28% are non-compliant.
Expect periodic returns similar to the FCA's existing REP-CRIM filing, with regular reporting of risk, control and incident data.
The FCA tests whether controls work in practice, not whether they are written in a manual. Expect staff interviews, sample file reviews and questions about how the MLRO actually signed off.
Personal responsibility for AML failings will be sharper under FCA supervision than under most current professional body supervisors.
FCA fines for AML failings have averaged around GBP 15 million per case in recent years across the wider supervised population, many multiples of the heaviest PBS-imposed penalties.
TCSP services, nominee director arrangements and company formation work treated as routine administration will be looked at much harder.
The compliance gaps most often found on inspection across the existing PBS regime. Each is an obligation the FCA will test.
A written assessment covering customers, geography, products and services, transactions and delivery channels, approved by senior management, reviewed regularly and referencing the UK National Risk Assessment. Most small firms have a templated BWRA that has never been meaningfully customised.
In force since 1 September 2022. Every firm must assess proliferation financing risk independently of money laundering and terrorist financing risk, referencing HM Treasury's national risk assessment. One of the most commonly missed obligations in small firms.
An independent function that evaluates the adequacy and effectiveness of AML controls, separate from the people who run compliance day to day. LSAG guidance expects this in all but micro-firms, typically every two years. A current Reg 21 audit is becoming the standard evidence of FCA-readiness.
Material discrepancies between your beneficial ownership findings and the Companies House register must be reported. Most small firms have never filed one. The FCA will look at filing rates per firm against substantial corporate client bases.
For high-risk relationships and property transactions, documentary evidence of the underlying source is required, corroborated by the bank trail. A bank statement alone is not sufficient. Conveyancing firms are particularly exposed.
Ongoing scrutiny of transactions and periodic refresh of client information throughout the relationship. Most small firms perform CDD at onboarding and never refresh it. Consistently the most common inspection finding across all PBSs.
Solicitors, barristers, notaries, licensed conveyancers and other legal practitioners in scope of the MLRs. Currently supervised by the SRA, Law Society, Council for Licensed Conveyancers and others.
Accountants, tax advisers, bookkeepers and insolvency practitioners. Currently supervised by ICAEW, ACCA, ICAS, ATT, CIOT, CIMA, AAT, IPA, IFA and others.
Company formation agents, registered office providers, nominee directors and trust administrators. Currently supervised by HMRC where not within a professional body supervisor.
Firms already supervised by the FCA under FSMA, including banks, investment firms, payment and e-money institutions and cryptoasset businesses, are not affected by this transition.
Founder Steve Middleton was Chief Administrative Officer of BNP Paribas Global Markets and is a current Non-Executive Director and Audit Committee Chair at a listed FCA-regulated stockbroker. The FCA's approach to professional services will draw on its existing financial-services playbook, which we know from the inside.
Fundsure is already HMRC AML supervised (XKML00000206994) and operates as an Authorised Corporate Service Provider. We have run professional services AML supervision end to end.
The large consultancies serve enterprise clients. We are deliberately built for sole-practitioner and small-firm work, the segment most exposed to the transition and least served by the existing market.
Fundsure is a member of the Association of Professional Compliance Consultants.
We provide expert review and drafting. The firm's MLRO retains the regulatory obligation.
We understand your firm's position and where the pressure points are.
A structured questionnaire, a document review and a written report with prioritised remediation actions.
Refresh the BWRA, rewrite policies and procedures, conduct a Reg 21 audit and deliver bespoke training.
Some firms move onto an outsourced MLRO retainer. All work is delivered remotely unless an onsite review specifically requires attendance.
The MLR obligations have been in force since 2017 and will not change. Investing now is investing in compliance you need regardless.
This page is general information, not legal or regulatory advice. Always check the current guidance from the FCA, HM Treasury and your supervisor, and take advice on your firm's specific circumstances.
Book a free 30-minute conversation about your firm's position, or ask for an FCA-Readiness Review. No obligation, just expert guidance from a firm that has lived professional services AML supervision.
