While the FCA brings data-driven strength and enforcement muscle, it must adapt its prescriptive model to professions used to autonomy and principle-based regulation. Dual oversight and potential overlap with conduct regulators could create confusion and cost.
Centralisation may bring consistency, but a one-size-fits-all approach risks alienating practitioners. As Hughes notes, success will depend on the FCA’s capacity to balance robust, risk-based supervision with proportionality—a true test of adaptability for the regulator now at the centre of the UK’s AML framework.




