The UK government has confirmed that all accountancy firms currently supervised by PBSs or HMRC will come under FCA AML supervision as part of the new Single Professional Services Supervisor (SPSS) model.
This is a major shift. The FCA is not a peer body or professional association. It is an enforcement regulator with investigative powers, and it expects evidence-based AML, not tick-box frameworks. If firms take a “wait and see” position, they risk walking straight into non-compliance.
Why This Change Matters for Accountancy Firms
PBS and HMRC supervision has historically been guidance-oriented. The FCA is outcomes- and enforcement-oriented. That means real operating controls, with evidence to back them.
Key differences include:
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More intrusive inspections
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Higher expectation of documented risk management
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Greater focus on ongoing monitoring, not just onboarding
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Board/senior accountability
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Public enforcement outcomes if compliance fails
“Good intentions” won’t cut it with the FCA. They assess culture, controls, governance and evidence.
What the FCA Will Look For
Accountancy firms should expect testing across:
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The Business-Wide Risk Assessment and whether it is live, not static
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Customer risk assessment with documented rationale
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CDD and EDD justification and evidence
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Ongoing monitoring logs and MI
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Whether the MLRO has real oversight, not delegated box-ticking
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Whether TCSP-style services inside the firm are risk-priced and governed
The FCA cares about what your firm does in practice, not what your policy says on paper.
[H2] The Risk of Doing Nothing
Many firms assume little will change, believing they “already comply with the regulations.” That assumption is exactly why firms will fail early FCA scrutiny.
PBSs rarely published enforcement.
The FCA does — and reputational damage can be immediate and lasting.
FCA supervision = public accountability.
What Firms Should Be Doing Now
The most effective early step is an FCA-style AML readiness gap analysis.
This tests:
- Evidence, not intention
- Real risk management, not template policy wording
- Senior accountability, not “the MLRO owns everything”
- Ongoing monitoring, not onboarding-only controls
- This identifies issues before the FCA does.
How AuthoriPay Helps
AuthoriPay supports firms through the transition by providing:
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FCA-style AML readiness gap analysis
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Policy and governance uplift to align with FCA expectations
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Preparation for FCA inspections and methodology
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File sampling and remediation planning
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MLRO and team uplift so controls operate effectively day-to-day
This is not a template rewrite. It is operational alignment with a real regulator.
Request an FCA AML Readiness Diagnostic by Contacting us Today
If you want to be FCA-ready before migration begins, now is the right time.
AuthoriPay is supporting firms in preparing for FCA AML supervision — including gap analysis, policy uplift and transition planning.
Contact AuthoriPay to arrange a confidential readiness review and transition plan.
FAQs
1. What does FCA AML supervision mean for accountancy firms?
FCA AML supervision means your accountancy practice will now be overseen by the Financial Conduct Authority instead of a professional body or HMRC. The FCA applies a risk-based, enforcement-focused approach, expecting evidence of ongoing monitoring, documented governance and senior accountability. Firms must align their AML frameworks with FCA standards to remain compliant under the new Single Professional Services Supervisor (SPSS) regime.
2. When will the FCA take over AML supervision for accountants?
The transition depends on primary legislation expected during 2025, with phased migration to FCA oversight from late 2025 or 2026. The government and FCA will publish a detailed transition plan once the legislation passes. Accountancy firms should start FCA-readiness reviews now to avoid a scramble when the new supervision begins.
3. Will small accountancy firms be treated differently by the FCA?
No. The FCA supervises proportionately based on risk, not firm size. Smaller firms offering higher-risk services (e.g., company formations, offshore structuring, or TCSP work) will face the same scrutiny as large practices. Every firm must demonstrate effective AML controls, up-to-date risk assessments and documented procedures consistent with FCA expectations.
4. What AML policies and procedures will need updating for FCA AML supervision?
Accountants will need to review their Business-Wide Risk Assessment, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), ongoing monitoring, and suspicious activity reporting procedures. The FCA will also expect detailed governance documents—clear MLRO responsibilities, management information, escalation logs, and audit trails. Firms should refresh policies and procedures now to match FCA AML supervision standards.
5. What records will the FCA expect accountancy firms to maintain?
The FCA requires evidence-based record keeping: client risk ratings, CDD documentation, transaction monitoring logs, internal audit results, staff training records, and Board-level AML oversight minutes. Under FCA AML supervision, firms must be able to prove that AML controls are operating in practice—not just written down in manuals.
6. Do accountancy firms need to appoint an MLRO under FCA AML supervision?
Yes. Every firm must have a designated Money Laundering Reporting Officer (MLRO) and a nominated officer responsible for suspicious activity reporting. The FCA expects both roles to be active, knowledgeable, and supported by documented reporting lines. The MLRO should produce regular AML MI for management and evidence independent oversight of compliance.
7. How can accountancy firms prepare for FCA AML audits or inspections?
Preparation begins with an FCA-style AML gap analysis. This identifies weaknesses in governance, customer due diligence, and ongoing monitoring controls before the FCA reviews them. Firms should implement an internal AML review schedule, retain all audit evidence, and train staff to handle FCA information requests quickly and accurately.
8. How can AuthoriPay help accountancy firms comply with FCA AML supervision?
AuthoriPay specialises in FCA AML readiness. We conduct gap analyses, uplift AML policies and procedures, and prepare firms for FCA inspections under the SPSS regime. Our consultants work with MLROs and compliance leads to ensure frameworks are proportionate, risk-based and fully aligned with the FCA’s supervisory expectations.
About AuthoriPay
AuthoriPay is a specialised consultancy firm providing regulatory compliance support to UK firms in the Fintech and NPPS sectors. The co-founders have over 40 years combined experience working directly for regulated firms and the consultancy practitioners that they rely on. AuthoriPay has significant experience in providing a wide range of safeguarding services, from audits to remediation work following reviews from regulators. AuthoriPay is fully versed in all matters of safeguarding compliance. AuthoriPay and its consultants are members of the Association of Professional Compliance Consultants and Advisory member of the Canadian MSB association. AuthoriPay is a Leader of the UK Payments Association.