Last week, the UK government announced that the FCA will assume responsibility as the Single Professional Services Supervisor (SPSS) for Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) supervision for the professional services sectors.
Under this model, the FCA will supervise firms in the legal, accountancy and trust and company services provider (TCSP) sectors – firms currently supervised by up to 22 Professional Body Supervisors (PBSs) and, in some cases, by HM Revenue & Customs (HMRC) for AML matters.
The shift is a structural reform: the consultation response states that “this policy will… integrate professional services into the FCA’s AML/CTF supervisory framework … simplifying a highly complex regulatory regime.”
For many AML compliance professionals in the UK, this landmark decision hails a new supervisory era where the lines between financial services-style regulation and professional services AML oversight are becoming much closer.
Why the change?
The background to this reform is worth setting out. In 2022, HM Treasury’s review of the UK’s AML/CTF supervisory regime found that while incremental improvements had taken place, “some weaknesses in supervision may need to be addressed through structural reform.” This prompted the consultation in 2023 on possible models, which included: enhancing the powers of the Office for Professional Body AML Supervision (OPBAS); PBS consolidation; a single professional services supervisor (SPSS); and a single AML supervisor (SAS).
The government concluded that an SPSS offered the most effective path forward. As they put it:
“The government believes that a public organisation overseeing professional services firms is the most effective approach to AML/CTF supervision of the sector. Integrating professional services into the FCA’s AML/CTF supervisory framework will bring professional services in line with all other sectors in scope of the MLRs, which are already overseen by public bodies, and it will simplify a highly complex regulatory regime.”
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From the compliance professional’s perspective, this change is motivated by a desire for more consistent oversight across the professional services sectors, better alignment with law enforcement, and the goal of simplifying the multiplicity of supervisors. The government estimated that the SPSS would supervise a population of approximately 60,000 regulated firms.
What compliance professionals should do now
Given the scale of change, here are practical actions you should take now to prepare your firm (and your AML compliance function) for the transition:
Map your supervisory status and upcoming switch-over: Confirm under which PBS or HMRC your firm is currently supervised for AML/CTF. Monitor the upcoming Treasury consultation (scheduled for early November 2025) on the FCA’s powers and keep an eye on transition materials from FCA and HM Treasury.
Review your AML/CTF framework against FCA-style expectations: Conduct a gap assessment of your policies, procedures, training, governance and control mechanisms. Ask: Is your firm operating in a way that evidences effectiveness (not just presence) of AML controls?
Prepare for dual-regulation challenges in the legal sector: Anticipate that AML/CTF oversight will shift but professional conduct regulation will persist separately. Clarify how supervision by the FCA will interact with the SRA (or equivalent industry specific regulator). Identify potential conflicts, any oversight overlap and set out how your firm will manage these.
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Engage with your professional body and sector-specific networks: Although the PBSs will relinquish AML/CTF supervisory responsibilities under this model, they will continue to have a role in professional standards, guidance, training and sector representation. Use your contact with them to stay informed about transitional issues, guidance updates, and possible changes to fee structures, registration systems or supervisory formats.
Monitor your internal resourcing and consider control-testing readiness: The government’s reform is ready to impose higher supervisory expectations and the FCA’s large supervised population (approx. 60,000 firms) means your firm’s AML/CTF controls may increasingly be in focus. Ensure your compliance team is appropriately resourced, you have internal audit or testing plans in place, clear escalation of issues to senior management, and you are capturing metrics and trends to demonstrate ongoing supervision of your AML/CTF controls.
Looking ahead: key milestones to watch
The FCA becoming the Single Professional Services Supervisor marks a major shift in UK AML and CTF oversight. From the October 2025 announcement through the phased transfer of firms under its supervision, compliance teams must stay proactive, plan for registration, fee adjustments, and data reporting, and address dual-regulation considerations. Firms that act early will be best placed to align their AML frameworks with FCA expectations and manage the transition effectively.
