On 2 December 2025, the Financial Conduct Authority (FCA) issued a public censure against the Institute of Certified Bookkeepers (ICB) for significant failures in its anti-money laundering (AML) supervision (read the full FCA publication here ). Although the FCA currently has limited powers over professional body supervisors (PBSs), this action represents the first time the FCA has disciplined a PBS, and it sends an unmistakable message: the standard of AML supervision across professional services must rise — and quickly.
This development is extremely relevant for accountants, lawyers, trust and company service providers (TCSPs) and other professional firms preparing to move under direct FCA AML supervision in the next few years.
What happened?
The FCA found that between January 2022 and July 2023, ICB:
- failed to adopt an effective, risk-based approach to AML supervision
- suspended all AML inspections for more than nine months
- had material deficiencies in its monitoring and oversight of over 3,000 supervised firms
- breached key obligations under the Money Laundering Regulations
The result was a public censure, the strongest sanction the FCA can currently impose on a professional body supervisor.
Although the FCA could not levy a financial penalty, the reputational impact is substantial — and that appears to be part of the intention. The FCA is making an example of weak AML oversight.
Why this matters for accountants, lawyers and TCSPs
The Government has already confirmed that these sectors will be moved under full FCA AML supervision, replacing the current mixture of PBS oversight and HMRC supervision. This censure gives a clear preview of the FCA’s mindset:
- The FCA expects robust, risk-based AML systems — not light-touch oversight.
Superficial compliance or “tick-box” approaches will be treated as unacceptable. - The FCA will not hesitate to take enforcement action.
This case shows the regulator’s willingness to call out failures publicly, even where its powers are limited. - Documentation and evidence matter above all else.
The FCA’s findings repeatedly reference failure to evidence monitoring, inspections, and risk-based activity. - The incoming regime for professional firms will be demanding.
Firms accustomed to PBS-style supervision will face a significant uplift in expectations.
What firms should do now
With tens of thousands of firms due to enter FCA AML supervision, registration windows are likely to be tight. In previous transitions (e.g., crypto), the FCA rejected the majority of applications and required many firms to stop regulated activities until their frameworks were corrected.
Legal practices, accountancy firms and TCSPs should begin preparing now by:
- updating firm-wide and client/matter risk assessments
- strengthening EDD processes and audit trails
- reviewing governance, reporting and senior management oversight
- ensuring policies and procedures reflect FCA standards, not PBS expectations
- conducting a structured FCA AML Gap Analysis to identify where uplift is needed
Early preparation significantly reduces the risk of missed deadlines, rejected applications or operational disruption later.
How AuthoriPay can help
AuthoriPay is already supporting professional services firms in preparing for the upcoming regime. We provide:
- FCA AML Gap Analysis
A structured review of your firm’s AML framework against FCA expectations, identifying gaps and required uplift. - Remediation and FCA Application Support
Enhancing policies, risk methodologies, EDD processes and governance, and preparing the full FCA registration pack.
We monitor deadlines and liaise directly with the FCA throughout the process.
To discuss how these changes will impact your firm, you can contact our AML team at aml@authoripay.co.uk or 01223 828266.
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.