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  • Writer's pictureDeborah

Launched on June 30 by the HM Treasury, the consultation seeks stakeholders feedback on the government proposal to reform the UK anti-money laundering and counter-terrorist financing (AML-CTF) supervisory regime.

Currently, the supervision framework is organized under 3 “Statutory supervisors”, namely the Financial Conduct Authority (FCA); the Gambling Commission (GC); and His Majesty’s Revenue and Customs (HMRC) that together sit alongside 22 PBSs (i.e. private bodies responsible for the AML/CTF supervision of the legal and accountancy sectors in the UK).

The consultation sets out four models that would improve the current regime :

  1. Office for Professional Body Anti-Money Laundering Supervision+ (OPBAS +): This model would require no structural change to the regime. OPBAS would be given enhanced powers to increase the effectiveness of supervision by the PBSs.

  2. Professional Body Supervisors (PBSs) Consolidation: Under this model two or six PBSs would likely retain responsibility for AML/CTF supervision. This model would retain the current system in which private bodies supervise firms, including representative bodies, but reduce inconsistency and complexity by ensuring only the highest performing supervisors remained.

  3. Single Professional Services Supervisor (SPSS): A single body will supervise all legal and accountancy sector firms for AML/CTF. It may also supervise some or all of the wider sectors currently supervised by HMRC. This body would most likely be a public body, unlike the PBSs and would be expected to be operationally independent of any ministerial department, but accountable to the Treasury.

  4. Single Anti-Money Laundering Supervisor (SAS): Under this model, all AML/CTF supervision in the UK would be undertaken by a single public body. The major difference between this and previous options is that the FCA and GC would also stop supervising firms for AML/CTF compliance.. An SAS would likely be operationally independent of any ministerial department, but accountable to the Treasury.

Comments are to be provided on or before 30 September 2023. The policy decision on the model and the key implementation considerations are scheduled for Q2 2024.

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