The UK Government has confirmed its decision to transfer anti-money laundering (AML) supervision from the current 22 accountancy and legal regulators, including CILEx Regulation, to a Single Professional Services Supervisor (SPSS). This role will be undertaken by the Financial Conduct Authority (FCA).
As of June 2026, HM Treasury has now published its response to the AML/CTF Supervision Reform: Duties, Powers and Accountability consultation. The response confirms the Government’s intention to proceed with legislative changes that will support the FCA’s future role as AML/CTF supervisor for legal service providers, accountancy service providers and trust and company service providers (TCSPs).
In its consultation response published on 21 October 2025, the Government outlined that implementation will require:
- Agreement on the FCA’s delivery plan, and
- Primary legislation, which will depend on parliamentary scheduling.
CILEx Regulation highlighted this development in its October 2025 newsletter to ensure CILEX members and supervised firms are aware of the changes.
The original consultation on reforming AML and counter-terrorist financing supervision was launched on 30 June 2023.
- Original consultation paper
- CILEx Regulation response – submitted 29 September 2023.
Following consultation with stakeholders, HM Treasury published its final policy response in June 2026. The response confirms the Government’s approach to registration, supervision, enforcement, information sharing, guidance, accountability and transition arrangements that will apply once AML/CTF supervision transfers to the FCA.
Government Policy Confirmed in June 2026
The Government has confirmed that:
- The FCA will maintain a public register of supervised legal, accountancy and TCSP firms.
- Firms carrying out regulated AML activity will need to be registered with the FCA.
- Regulation 58 fit and proper testing will be extended to legal and accountancy service providers.
- The FCA will apply a risk-based supervisory approach and will have powers to conduct inspections, request information, appoint skilled persons and issue directions.
- Existing legal professional privilege protections will remain unchanged.
- Existing whistleblowing protections will remain in place.
- Professional bodies and the FCA will be required to cooperate and share information in order to reduce duplication and minimise regulatory burden.
- OPBAS will continue during the transition period but will cease once the FCA has fully assumed AML supervisory responsibilities.
What This Means for You
- No Immediate Change: CILEx Regulation will continue to act as your AML supervisor until the transition is complete.
- Future Supervision by FCA: Once implementation is complete, the FCA will become the AML/CTF supervisor for legal service providers, accountancy service providers and TCSPs. Firms can expect a registration regime operated by the FCA, risk-based supervision, information gathering powers, inspections and an expanded supervisory framework.
- Impact on Processes: Firms should expect changes relating to registration, fit and proper testing, supervisory information requests, inspections, reporting arrangements, guidance approval processes and enforcement procedures once the FCA assumes responsibility. Detailed implementation arrangements will be communicated as they become available.
- Stay Informed: We will share updates on timelines and practical implications as soon as they are confirmed.
FAQs
- When will the FCA take over AML supervision? There is no confirmed implementation date yet. HM Treasury has confirmed that further primary and secondary legislation will be required, together with FCA implementation planning and transitional arrangements before the new regime can go live.
- Do I need to change anything now? CILEx Regulation remains your AML supervisor until the transition is complete. Continue to follow current requirements.
- Will my firm’s AML obligations change under the FCA? The underlying Money Laundering Regulations remain in place. However, firms can expect changes to registration requirements, supervision arrangements, inspections, information requests, guidance processes and enforcement arrangements once the FCA becomes the AML/CTF supervisor.
- Will CILEx Regulation still provide AML guidance?
Yes. CILEx Regulation will continue to provide guidance and support during the transition period. Following implementation, responsibility for approving AML/CTF guidance for professional services firms is expected to transfer to the FCA, although practitioner involvement in drafting guidance is expected to continue. - Where can I find updates? Updates will be published on our website and in member newsletters as further information becomes available.
- Will firms need to register with the FCA? Yes. HM Treasury has confirmed its intention for the FCA to maintain a register of professional services firms carrying out regulated AML activity. Registration with the FCA will be required to lawfully undertake regulated activity within scope of the Money Laundering Regulations.
- Will legal professional privilege still apply? Yes. The Government has confirmed that the existing protections contained within Regulation 72 will remain unchanged. The FCA will not be able to require disclosure of information that is protected by legal professional privilege.
Next Steps
HM Treasury and the FCA will continue to develop the implementation framework for the new supervisory regime. Further detail is expected regarding:
- FCA registration processes
- Supervisory fees
- Transition arrangements
- Information-sharing arrangements
- Guidance approval arrangements
- Implementation timelines.
CILEx Regulation will continue to update members and supervised firms as further information becomes available.
