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31 October 2025 / Rebecca Hughes
Issue: 8137 / Categories: Opinion , Profession , Regulatory
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A new era for AML supervision

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Ambitious plans to transform the FCA into a super regulator will test the organisation’s capacity & adaptability, but the true test will be in delivery, says Rebecca Hughes

After two years of deliberation, the government has finally published its response to the 2023 consultation on reforming the UK’s anti-money laundering and counter-terrorism financing (AML/CTF) supervisory regime. The Financial Conduct Authority (FCA) has been crowned the Single Professional Services Supervisor (SPSS), a surprising outcome for many, not least the professions that will now fall under the FCA’s oversight.

The UK system currently comprises three statutory regulators—the FCA, HM Revenue & Customs (HMRC) and the Gambling Commission, alongside 22 Professional Body Supervisors (PBSs) overseeing the legal and accountancy sectors. Each PBS is responsible for ensuring that its supervised population complies with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs).

This structure has long attracted criticism. The 2015 national risk assessment (the UK’s first comprehensive assessment of money laundering and terrorist financing risk) first

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Private prosecutors face closer scrutiny under Crown Prosecution Service guidance designed to strengthen accountability and consistency when intervention is requested
Foreign states cannot necessarily claim immunity for cyber operations launched abroad against computers in Britain, following a divided Supreme Court ruling
Defendants who make unsupported complaints about their lawyers risk losing legal aid while confiscation proceedings continue without representation
Lawyers advising Russian clients face different sanctions restrictions across the UK, EU and US, despite their shared objective of increasing pressure on Russia
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