FCA Takes Charge: UK Centralises AML Supervision Across Professional Services

The United Kingdom’s decision to centralise Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) supervision under the Financial Conduct Authority (FCA) marks a structural shift that brings professional services oversight in line with the rest of the financial sector. The move aligns the UK with a broader global trend toward consolidation, consistency, and intelligence-led supervision – a model increasingly mirrored in the European Union (EU) and, in more complex form, across U.S. agencies.

In its October 2025 consultation response, HM Treasury confirmed that the FCA will assume responsibility for AML and CTF supervision of legal, accountancy, and trust and company service providers – approximately 60,000 firms previously overseen by 22 professional body supervisors (PBSs) and His Majesty’s Revenue and Customs (HMRC).

The FCA’s data-driven supervisory approach is expected to enhance risk assessment and early identification of weak controls. By integrating AML responsibilities into an existing public regulator, the UK is betting on scalability and consistency rather than reinventing the wheel. Implementation will depend on forthcoming legislation and a separate consultation defining the FCA’s powers, fee model, and accountability mechanisms.

Why Consolidation Matters

The FCA’s new remit does more than merge bureaucracies – it redefines the UK’s second line of defence against illicit finance. Under the previous system, fragmentation across more than 20 PBSs hindered information sharing and created uneven enforcement. The new framework allows the FCA to apply a risk-based approach across its enlarged supervisory population, focusing resources on higher-risk firms while maintaining proportionality for smaller practices.

Europe’s Parallel Path

Across the Channel, the EU is implementing its own far-reaching AML and CTF transformation through the creation of the Anti-Money Laundering Authority (AMLA), headquartered in Frankfurt. Established under Regulation (EU) 2024/1620, AMLA began operations in July 2025 with direct supervision phased for selected high-risk entities and coordination with national supervisors for others.

The AMLA initiative forms part of the EU’s broader AML Package, which also introduces a directly applicable Anti-Money Laundering Regulation (AMLR) from 2027 and a Sixth AML Directive (6AMLD) to strengthen cooperation among Financial Intelligence Units (FIUs). Together, these measures aim to harmonise rulebooks across member states and enhance cross-border data sharing.

In parallel, the European Securities and Markets Authority (ESMA) has extended its supervisory reach under the Markets in Crypto-Assets Regulation (MiCA), publishing guidelines to detect market abuse and financial crime risks in crypto trading. This reinforces a holistic EU approach where AML, sanctions, and market surveillance converge under a shared digital and data-driven umbrella.

The EU’s architecture differs from the UK’s national model: AMLA operates above national regulators, while the FCA’s SPSS consolidates oversight within a single domestic body. Yet both represent a clear policy direction – towards centralised authority, common standards, and coordinated intelligence-sharing.

The United States: Reform by Fragmentation

While the UK and EU pursue structural consolidation, the United States remains defined by a multi-agency framework, with the Financial Crimes Enforcement Network (FinCEN), Securities and Exchange Commission (SEC), and prudential regulators sharing oversight responsibilities. Recent developments reveal progress – and continued complexity.

FinCEN’s long-awaited AML and Suspicious Activity Reporting (SAR) rule for investment advisers, finalised in 2024, was delayed until 2028 following industry consultation and court rulings in late 2024–early 2025 prompting FinCEN to pause and then remove the domestic BOI reporting mandate. Foreign entities are still required to report.

At the supervisory level, the Federal Reserve recently shifted emphasis away from “reputational risk” assessments toward more concrete measures of control effectiveness, reflecting a move toward operational accountability. The SEC, for its part, continues to enforce AML and record-keeping obligations through high-profile actions against broker-dealers and trading platforms, particularly for off-channel communications and market access violations.

The result is a patchwork system where innovation in one area is often offset by delay in another. Without a single coordinating body like the FCA or AMLA, U.S. AML supervision remains distributed across multiple agencies – adaptable, but fragmented.

Sanctions Oversight: An Expanding Frontier

The UK’s reform process also addressed sanctions supervision. Since Russia’s 2022 invasion of Ukraine, UK supervisors have taken a more proactive stance, issuing enhanced guidance and monitoring programmes.

The EU’s AML package formalises coordination on sanctions enforcement across member states, while U.S. authorities – notably the Office of Foreign Assets Control (OFAC) – continue to rely on extensive enforcement powers. Across jurisdictions, sanctions compliance is increasingly integrated into broader AML and financial crime frameworks, reinforcing the case for unified data architectures and shared intelligence channels.

Implications for RegTech and Compliance Teams

For compliance and technology leaders, these developments point to an era of data-led regulation. Firms operating across jurisdictions will need to reconcile diverse supervisory expectations into coherent compliance architectures that support:

• Data standardisation and reporting automation to satisfy FCA, AMLA, and FinCEN requirements.
• Explainable artificial intelligence (AI) in transaction monitoring, sanctions screening, and crypto surveillance to meet emerging transparency standards.
• Modular RegTech architectures, enabling adaptation between the harmonised EU/UK regimes and the multi-layered U.S. approach.
• Cross-border interoperability – especially for beneficial ownership data, where U.S. retrenchment contrasts sharply with UK and EU transparency drives.

Toward a New FinCrime Equilibrium

The FCA’s new supervisory role signals the UK’s shift from a fragmented network to a focused, risk-based regime designed for scale, coordination, and intelligence-sharing. The EU’s AMLA follows a similar trajectory, embedding harmonisation at the continental level. By contrast, the United States continues to modernise within its distributed architecture, balancing innovation with institutional complexity.

Together, these models reflect a global movement toward supervisory consolidation and data-driven enforcement. The next challenge lies not in defining the rules, but in connecting the systems – ensuring that regulators and firms alike can trace, trust, and act on financial crime intelligence across borders.