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Anti-money laundering (AML) supervision continues to face challenges, with significant improvements still required among professional body supervisors (PBSs), according to a new report by the Office for Professional Body Anti-Money Laundering Supervision (OPBAS). The report stresses the need for more robust and proactive measures to address shortcomings in AML supervision and ensure effective enforcement of AML regulations.

Inconsistent Effectiveness Among AML Supervisors

OPBAS’s fifth annual report on supervision reveals that while PBSs are generally complying with regulations, their effectiveness in supervising their members is still inconsistent. The report highlights that many PBSs have not made material improvements in critical areas, such as adopting a risk-based approach, effective enforcement, and information sharing.

In fact, out of the nine PBSs evaluated, most showed little to no improvement, with incremental progress observed in only three. OPBAS had to intervene in two cases to address significant inefficiencies in compliance and supervision.

The report makes it clear that there is still a long way to go for PBSs to become fully effective in their roles as Anti Money Laundering supervisors. Weaknesses in supervision could lead to increased risks of money laundering activities going undetected, making it imperative for PBSs to address these issues urgently.

Key Areas of Concern in AML Supervision

The report identifies several areas where PBSs are falling short in their supervision responsibilities:

  • Risk-Based Approach: OPBAS noted that many PBSs lack a well-defined methodology to supervise their members based on risk. This shortfall hampers their ability to focus resources on high-risk entities, undermining the overall effectiveness of supervision.
  • Enforcement: The report highlights the inadequate use of enforcement powers by many PBSs. Despite an increase in non-compliance findings, the number and value of fines issued have declined. This weak enforcement diminishes the credibility of PBSs as deterrents to money laundering.
  • Inadequate Resources: One of the most concerning findings is that some PBSs are not allocating sufficient resources to their AML supervisory functions. Without adequate funding and staffing, their ability to supervise effectively is compromised. Some PBSs were found to spend as little as £73 per supervised entity, while others spent over £1,000, suggesting vast discrepancies in commitment to anti money laundering efforts.
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Outsourcing of AML Supervision

A significant issue highlighted by OPBAS is the reliance on third-party subcontractors by some PBSs to conduct anti money laundering supervision and inspections. The report found that subcontracted inspectors were often not fully aware of PBSs’ policies and risk profiles, leading to inconsistencies in how supervision was carried out.

This outsourcing of critical functions, without adequate oversight, raises concerns about the overall effectiveness of PBSs in preventing money laundering. OPBAS stresses that PBSs must maintain strong oversight of any outsourced activities to ensure that their AML supervision is carried out effectively and in line with regulations.

Need for Proactive Actions

OPBAS has called for PBSs to take more proactive actions to strengthen their AML supervision efforts. The report warns that without substantial improvements, the UK could see an increase in illicit funds entering its financial system.

To address these concerns, OPBAS has outlined several steps it plans to take in the coming year:

  • Supervisory Oversight: OPBAS will continue its active oversight of PBSs and will intervene where necessary to address failings. This includes using the tools and powers within the current AML framework to enforce compliance and drive improvements.
  • Focus on High-Risk Areas: OPBAS will maintain its focus on high-risk areas and emerging issues, engaging with PBSs to ensure that lessons are incorporated into their supervisory approaches.
  • Enhanced Expectations: OPBAS has raised its expectations for PBSs and has updated its sourcebook to reflect clearer outcomes and stronger guidelines for effective AML supervision.

The Importance of Strong AML Supervision

Effective AML supervision is critical in the fight against financial crime. By ensuring that PBSs are effectively monitoring and enforcing AML regulations, the risk of illicit funds entering the UK financial system can be significantly reduced. However, the OPBAS report makes it clear that more work is needed to achieve this goal.

PBSs play a key role in safeguarding the UK economy from the risks associated with money laundering. It is essential that they not only comply with regulations but also take a proactive approach to supervising their members, enforcing penalties where necessary, and sharing information and intelligence to prevent money laundering activities.

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The Road Ahead for AML Supervision

While the OPBAS report acknowledges some improvements in AML supervision, it also highlights that much more needs to be done. Without substantial changes to the way PBSs operate, the UK risks falling short in its fight against money laundering and financial crime.

At K2 Accountancy Group, we recognise the critical role that AML supervision plays in maintaining the integrity of financial systems. As AML regulations evolve, we are committed to helping businesses stay compliant, ensuring they meet the highest standards of supervision and enforcement.

If your business needs expert guidance on AML compliance, K2 Accountancy Group can provide the support you need to navigate this complex landscape. Contact us today to learn more about how we can assist with your AML obligations and help you stay ahead of regulatory changes.


By focusing on AML, businesses can ensure they are well-prepared to meet the increasing demands of regulatory oversight. Strong AML practices not only protect businesses from financial crime but also enhance their reputation in a highly competitive market.

Please note that all information presented in this article is general and should not be considered advice from K2 Accountancy Group. Please contact us directly for specific advice on your own circumstances.