Recovering the costs of OPBAS: further consultation on fees structure
Executive summary
- AAT strongly supports the UK’s drive to combat money laundering and terrorist financing. AAT also recognises that establishing consistency within the anti-money laundering (AML) regime in the UK is paramount.
- AAT is disappointed by the further delays the PBSs are encountering in being finally advised as to the fees due, relating to OPBAS supervision. Having been previously advised that the invoices for 2018/19 would be issued in Q1 2019, to now be advised that they will not be issued until August 2019 at the earliest, to be shortly followed by the 2019/20 invoices, represents what should have been an avoidable burden on all PBSs.
- The basis for this consultation paper appears to be that there is a fundamental divide in the opinions of those PBSs that fall above the minimum fee threshold of 6,000 supervised individuals and those that fall below it. AAT contends that this was always likely to be the stance taken by the PBSs according to their relationship with the threshold and is therefore unsure as to why the FCA would not have anticipated this. The need for two further consultations on this (CP19/13 and a subsequent consultation due in July 2019) and the further delay this is causing is questionable in AAT’s view.
- AAT does not agree with the removal of the minimum fee structure. Given that the FCA has engaged an internal review on the OPBAS fees consultations conducted since 2017, concluding that the tariff measure of supervised individuals remains the most suitable, and that the 6,000 supervised individuals is a reasonable point at which to set the minimum fee threshold, AAT sees no reason to challenge those conclusions.
- The direct impact on AAT of removal of the minimum fee threshold would see a real terms increase in the 2019/20 financial year of 77% relating to AAT’s spend on AML supervision. On an annual basis this percentage increase is reduced to 38%, nevertheless there is no realistic scope to recover this from the licensed membership that AAT supervises for AML purposes in the current year.
Related consultation responses
Improving the effectiveness of the Money Laundering Regulations
AAT supports the government’s drive to combat money laundering and terrorist financing and to ensure that UK businesses are appropriately supported.
Spring Budget 2024 representation
This representation ahead of the March 2024 Spring Budget sets out AAT’s policy position on tax, professional standards, support for SMEs and late payments.
Reforming anti-money laundering and counter-terrorism financing supervision
AAT contends that the OPBAS+ model is the most suitable option and would result in a demonstrable improvement in the sector.
