Insights · Regulation, registers and professional boundaries

The FCA's New AML Supervisor — and It's the One Your Introducer Partner Already Answers To

9 min read · Altro Partners, by Equity & General

Reacting to: Financial crime: protecting the hive — speech by Steve Smart, FCA Executive Director of Enforcement and Market Oversight (Financial Conduct Authority, 17 September 2026) →

Speaking at the Law Society's Economic Crime Conference on 17 September, the FCA's Steve Smart confirmed something accountancy firms have been half-expecting for a while: anti-money-laundering supervision of around 60,000 legal and accounting entities is moving to the FCA, at what he called "the backend of 2028." Money Marketing picked the story up the next morning under the plainer headline that it was a takeover of AML supervision for the sector. Both descriptions are correct, and both undersell what is actually interesting about it.

The interesting part is not the transfer itself — regulatory reshuffles happen. It is what this does to the relationship between two professions that already sit either side of most business owners' financial lives. Financial planners already answer to the FCA for their AML controls, because they answer to the FCA for everything. Accountants, for the most part, do not. By 2028, for the first time, both halves of a joined-up accountant-and-planner relationship will be checked by the same regulator on the same question: do you actually know who your client is, and can you prove it. That convergence is worth understanding now, while there is still time to do something useful with the two years' notice.

What Smart actually said, and what it does not yet tell you

The headline figure is 60,000 — the number of legal and accounting entities the FCA expects to take on. The timeline is "the backend of 2028," which is a phrase from a speech, not a date from a statutory instrument. Smart framed the move as playing to the regulator's existing strengths: he described the FCA as "a multidisciplinary organisation with almost 400 practising lawyers," and pointed to intelligence systems that "process over 56 million records every day and flag high-risk firms earlier than we could before." His stated intention was a supervisory approach that is risk-based and proportionate rather than uniform — in his words, "our focus is on criminals, not firms doing the right thing," and, more directly still, "if you're trying to do the right thing, we're not looking to catch you out."

Two other figures from the same speech are worth knowing, because they will circulate in isolation and get overstated. Smart cited a £100 million annual saving as an example of what the FCA's more proportionate approach has already delivered elsewhere, through changes to transaction reporting requirements — not a saving specific to accountancy firms, and not a promise about what firms newly under FCA AML supervision will see on their own bill. And he noted that the reporting threshold for Defence Against Money Laundering requests has been raised to £3,000, on the reasoning that "the old threshold generated too many low-value reports and tied up resource." That is a genuine simplification, and it is a general one across regulated sectors, not a bespoke concession to accountancy.

What the speech did not do is set out a transition mechanism. It did not say whether the professional bodies that currently supervise most accountancy firms for AML purposes hand over in a single date, in phases, or retain some ongoing role. It did not publish a consultation paper, a draft rulebook, or a fee schedule. Those are the practical questions a firm actually needs answered before 2028, and none of them exist yet in public form. What exists is a stated direction and a confirmed regulator — enough to plan around, not enough to act on operationally today.

Why the FCA wants this — and why it is framed as urgent now

Smart's speech leaned on scale to make the case: fraud, he said, "accounted for nearly half of all crime in England and Wales last year," and he cited estimates that "over £100bn is laundered through or within the UK each year." His central image was a beehive — "every bee gets checked at the door. If something's off, the colony responds — together, and quickly" — used to argue that fragmented supervision across dozens of professional bodies leaves gaps that a single, technology-enabled supervisor would not. Whether or not the metaphor lands, the underlying argument is a familiar one in UK financial regulation: consolidate supervision under the body with the most data, and treat firms behaving properly with a lighter touch than firms that are not.

For the first time, the professional checking a client's identity for tax purposes and the professional checking it for investment purposes will be marked against the same regulator's rulebook — even though neither one's job changes.

Where this actually bites: the handover, not the headline

Take a mid-sized general practice that already introduces clients to a financial planner under a formal partnership arrangement — the kind of relationship this site describes in the anatomy of an introduction. Today, when a director is introduced for advice on surplus cash sitting in the company, two entirely separate AML regimes run in parallel without ever comparing notes. The accountancy firm's client due diligence sits with its professional-body supervisor, built around the checks that make sense for tax and accounts work. The planner's client due diligence sits with the FCA, built around the checks that make sense for investment business. Both firms know the same director. Both have already verified who they are. Neither process talks to the other, so identity is effectively re-established from scratch on the second side of the handover, using different documentation standards, different retention rules and — in practice — a client who is mildly irritated at being asked for their passport twice inside a fortnight.

That duplication is not this week's problem, and 2028 will not erase it entirely — an introducer relationship will still involve two separate firms doing their own due diligence, because that is a feature of the arrangement, not a defect the FCA is fixing. What changes is that both firms' due-diligence standards will eventually be set and inspected by the same regulator, using broadly the same risk-based logic. That does not merge the two checks into one. It does mean that when a practice manager on one side asks a compliance officer on the other "what do you actually need from us for a referred client," the honest answer stops being "we operate under different rulebooks, so I'm not sure" and starts being a comparison of two processes governed by the same supervisor's expectations. That is a smaller, more answerable question, and it is the kind of thing that gets fixed in practice rather than legislated away.

Two things to do this week

First — and this sits alongside, not instead of, the tax adviser registration deadline covered in this site's earlier piece on MMTAR — locate your firm's current AML supervision certificate and confirm it is genuinely current and available digitally. That document does not become less important because a future regulator is confirmed; if anything, a firm with tidy AML paperwork today is the firm that finds a supervisory handover in 2028 uneventful rather than urgent.

Second, if your firm has an active referral relationship with a financial planner, ask them directly this month how they run client due diligence on a client your firm introduces, and what they would ideally receive from you to avoid re-doing work you have already done. You will very likely find the answer is "nothing formal exists," because most introducer relationships have never needed to compare notes on this specific point. That gap is worth naming now, two years before a shared regulator gives both sides a reason to close it, rather than discovering it under time pressure later.

What is genuinely still unsettled

Three things are open, and it would be dishonest to pretend otherwise. The transition mechanism — whether professional-body supervisors step aside in one move, in stages, or retain a residual role — has not been published. The cost and fee implications for accountancy firms moving from their current supervisor's fee structure to the FCA's are unknown, and Smart's £100 million saving figure describes a different part of the regulatory perimeter, not this one. And the precise date within "the backend of 2028" has not been narrowed, which matters less for planning purposes than the direction itself, but matters a great deal to any firm trying to time a supervisory renewal against it. All three are the kind of detail that arrives via a technical consultation rather than a conference speech, so they are worth watching for over the next year rather than guessing at now.

The wider point this sits inside

None of this closes the advice gap by itself, and it was never designed to. The lang cat's State of Advice Report 2025 found that just 9% of UK adults had paid for financial advice in the preceding two years, while 91% of those who did found it valuable — a profession serving a narrow group well and reaching very few people outside it, as this site sets out in full on the advice gap. Supervisory convergence is scaffolding, not the conversation itself. But scaffolding that removes friction from the handover between the professional a business owner already trusts and the one who can act on what they see is not nothing. It is one more small reason for that handover to happen at all, which remains the actual bottleneck.

Common questions

When exactly does this change take effect, and does it apply to my firm now?

Not yet, and not precisely. Steve Smart's speech put the timeline at "the backend of 2028" for the FCA to take on anti-money-laundering supervision of the roughly 60,000 legal and accounting entities currently supervised elsewhere. That is a direction of travel announced in a conference speech, not a commencement date fixed by published rules — the FCA has not yet issued the consultation paper or transitional timetable that would tell an individual firm which quarter it moves, what it needs to submit, or what a first FCA-run inspection looks like. For now nothing changes in how your firm is supervised. What has changed is that the destination is confirmed, which is enough to start thinking about it two years out rather than being caught by it in 2028.

Does this change what an accountant can say to a client about financial advice?

No, and this is worth being precise about because two separate things share the letters AML and FCA. Anti-money-laundering supervision governs your firm's own controls — client due diligence, risk assessment, suspicious activity reporting — and who checks that you are doing that properly. It has nothing to do with the boundary around regulated financial advice. Noticing that a client has surplus cash, no protection in place or a business sale in motion remains observation, and it is yours to make. Recommending a specific pension, investment or product remains a regulated activity that belongs with an FCA-authorised advice firm. Coming under the same regulator for AML supervision does not blur that line; if anything, sitting inside the same regulatory family as the planner you refer to makes the two positions easier to state plainly to a client.

Which body supervises accountants for AML now, and does that disappear straight away?

Most accountancy firms currently sit with one of the professional-body supervisors that operate under the UK's 2017 Money Laundering Regulations regime, rather than with the FCA directly. Steve Smart's speech confirmed the destination — FCA supervision of the sector — but did not set out a transition mechanism, so it is not yet public whether the existing supervisors wind down in one move, hand over in phases, or retain some role alongside the FCA. That detail matters operationally — it decides who you renew your supervision with next year, and the year after — and it is exactly the kind of thing that tends to arrive as a technical consultation rather than a headline, so it is worth watching for rather than assuming.

What should our firm actually do about this now, more than two years before it lands?

Two things, both low-effort. First, locate your current AML supervision certificate and confirm it is live, current and held digitally — you need this anyway for HMRC's tax adviser registration regime, and it is the one document that will matter whoever is supervising you in 2028. Second, if your firm refers clients to a financial planner, ask them this year how they run client due diligence on a referred client, and note where it duplicates or conflicts with your own process. That is not a task the 2028 change requires of you — it is a task worth doing regardless, because it is the friction that shows up every time a client is handed between two firms today, and understanding it now means you are not starting from zero whenever supervision does converge.

Will this make it easier to refer a client to a financial planner?

Possibly, eventually, and not by itself. An introduction already works without any change here: your firm observes a signal, the client consents, the planner takes over the regulated advice, and a summary comes back to your file. What the 2028 change removes over time is a specific piece of friction underneath that process — the fact that the accountant's AML supervisor and the planner's AML supervisor are, today, entirely different organisations with different expectations, different inspection regimes and different forms. Once both professions answer to the same regulator for how they check who a client is, aligning the due-diligence paperwork on each side of a handover becomes a technical conversation rather than a cross-regulator one. That is a smoother pipe, not a different destination.

More on this

Where one profession's role ends and the other begins

Supervision, registration and authorisation all point at the same practical question: who is responsible for what, and how a client is handed between the two without anything falling down the gap.

Read: who does what → All insights