Are You Prepared for AML Supervision Reform?

What Professional Services Firms Need to Know Now

The UK government’s consultation on reforming how anti-money-laundering and counter-terrorist financing (AML/CTF) supervision is carried out across parts of the professional services sector closed on 24 December 2025. The consultation examined the duties, powers and accountability framework that would be required for a future model in which the Financial Conduct Authority (FCA) becomes the single AML supervisor for certain professional services firms.

Crucially, these reforms are not intended to apply to all MLR-regulated sectors. The proposals are focused on three specific categories of professional services:

1. Legal service providers within scope of the MLRs

2. Accountancy service providers (including tax advisers and audit firms)

3. Trust and Company Service Providers (TCSPs)

These are the sectors that would, under the proposed model, move to FCA AML supervision once the reforms are implemented.

Other sectors, including estate agents, letting agents, high-value dealers, art market participants and cryptoasset businesses, remain outside this consolidation proposal and would continue under their existing supervisory arrangements unless future policy changes are announced.

For firms in legal, accountancy and TCSP sectors, this reform should therefore be viewed as directly relevant and operationally significant, even though implementation will take place over a phased period.

Where things stand now

The consultation did not revisit the question of whether consolidation should take place. The policy direction towards a single FCA-led supervisor for these professional services sectors has already been set, and the consultation focused instead on how the FCA’s supervisory powers, registration approach, perimeter enforcement and risk-based methodology should be structured.

Responses have now been submitted and are being reviewed by HM Treasury and the FCA. The next stage will be the publication of a formal consultation response and an accompanying legislative pathway. Because the reforms require primary legislation, the timetable will depend on parliamentary priorities and delivery planning.

What this means in practice for legal firms, ASPs and TCSPs

Even though the transition will not happen overnight, firms in scope should use this period to strengthen their position rather than waiting passively.

Three priorities stand out.

First, be clear on whether your firm’s activities fall within the MLR-regulated definitions for your sector. This will determine whether you are part of the future FCA-supervised perimeter.

Second, review the maturity and evidential quality of your AML framework with an eye toward FCA-style expectations — particularly risk assessment methodology, governance, auditability of decisions, documentation standards, and ongoing monitoring.

Third, be prepared for greater supervisory consistency and more structured engagement than is typical across some PBS-supervised environments today.

Firms that approach this as an upgrade opportunity rather than a compliance disruption are likely to transition more smoothly.

Coventium’s perspective

At Coventium, we see this reform as a pivotal moment for firms in the legal, accountancy and TCSP sectors.

Our unique expertise within the TCSP, ASP and legal services sectors, is combined with many years of experience delivering assurance, testing and remediation for FCA-regulated firms. This

allows us to help professional services firms bridge the gap between current supervisory expectations and what a more rigorous, risk-based supervisory model is likely to require.

If you are unsure whether your firm falls within scope of the proposed reforms, or you want to understand how well your existing AML framework would stand up to FCA-style scrutiny, this is an ideal time to review and prepare rather than wait for formal transition.

Contact Us