Anti-money laundering supervision reform: key developments
The UK Government is introducing changes to the anti-money laundering and counter-terrorist financing (AML/CFT) supervisory framework. These reforms will reshape how AML/CTF supervision is carried out across the accountancy and legal sectors.
HM Treasury and the Financial Conduct Authority (FCA) are developing a new model aimed at improving consistency, strengthening oversight, and reducing fragmentation across the current system.
If you're supervised by AAT for the purpose of the AML compliance, your current AML/CTF supervisory responsibilities remain unchanged.
All updates on this page will relate specifically to the supervisory reform, not to your ongoing compliance duties. This information continues to be available on our AML page.
We also regularly publish AML/CTF‑related articles on AAT Comment and the Knowledge Hub, which we encourage you to engage with.
AAT's role in the transition
We are:
- engaging regularly with HM Treasury and the FCA to understand what the new arrangements will involve and how the transition will be implemented
- feeding in insights and concerns from our licensed members
- preparing for the operational aspects of transition
- ensuring members receive accurate, timely and consistent information.
We act as your main point of contact for anything relating to supervisory reform.
Key facts
If AAT is your AML supervisor, your responsibilities remain the same. We'll continue as your supervisor during the transition period and all current requirements, reporting processes and expectations will apply until the new supervisory arrangements formally come into effect.
All your AML-related obligations remain in full effect – including undertaking client due diligence, reporting, training and record keeping.
Supervision of AML/CTF compliance will transition to the FCA. The timing of the transition is unconfirmed but we'll inform you of any updates. Until then we remain your AML supervisor and there is no change to how you interact with us.
At this stage, no action is required from you. If any steps become necessary later, we'll give you clear guidance and enough notice to prepare.
Latest updates
Where there are developments this section will cover:
- progress in our discussions with the FCA and HM Treasury
- any new information released by government or regulators
- details of transition plans as they are confirmed
- relevant documents or statements issued during the transition period.
Most recent update
Feedback
When HM Treasury or the FCA publish consultations, we'll detail them here along with deadlines and guidance on how you can respond.
Where appropriate, we may also collect member feedback to inform our engagement with government.
The next planned consultation will focus on the FCA's fees, but no timeframes have been announced yet.
Contact us
If you have questions about the supervisory reform or how it will affect your firm, contact our team at amlconsultation@aat.org.uk.
