Reforming anti-money laundering and counter-terrorism financing supervision
Our response published
28 September 2023
- AAT has always maintained a stance of strong support for the UK’s drive to combat money laundering and terrorist financing.
- AAT recognises the role that the accountants play as gatekeepers to financial probity and is fully aligned with the ambition as captured in the consultation to strengthen the effectiveness of the anti-money laundering and counter-terrorism financing (AML/CTF) supervisory regime.
- Whilst it may appear more straightforward to have one supervisor it is AAT’s assertion that this would inevitably be fraught with significant risk.
- AAT therefore contends that the OPBAS+ model is the most suitable option and would result in a demonstrable improvement in the sector. The rationale behind this view is that by granting OPBAS with broader and stronger powers it would be better able to hold those underperforming PBSs to account and best meet the government’s objective to ensure greater consistency of supervision without jeopardising current performance.
- Options 2, 3 and 4 are fraught with risk in particular. The transition process, requiring the transfer of data and information from the deselected PBSs in transition to any of models 2, 3 or 4 represents a sizeable challenge which could in itself result in severe disruption to AML supervision and subsequently an increase in non-compliance.
- Given the complexities involved in supervision, and the variety in type and sizes of firms in each of the two sectors, replicating the expertise and knowledge that is currently held by the existing PBSs will be a significant challenge.
- Given that the stated aim is to be able to demonstrate improved effectiveness ahead of the next assessment of the UK’s AML/CTF regime by FATF, this ignores the fact that the implementation of any significant reform in the AML/CTF supervisory landscape is likely to take a number of years to fully implement, a fact that is readily applicable to models 2, 3 and 4.
Related consultation responses
Office for Professional Body Anti‑Money Laundering (OPBAS) sourcebook update
We welcome the review of the sourcebook and are in support of the proposed changes. However, we question the clarity and accuracy of the cost analysis.
CP22/7: FCA regulated fees and levies: rates proposals for 2022/23
AAT questions the lack of transparency provided to professional body supervisors concerning this consultation and the clarity of the consultation paper.