Changes to the oversight of Anti-Money Laundering work by professional firms

14 November, 2025

As many of you will know, the government has decided that AML supervision in the UK for certain sectors (including the legal sector) will be transferred to the Financial Conduct Authority (FCA). This means that all AML supervision for CLC practices will be overseen by the FCA at a certain point in the next few years (the precise date is currently unknown but we will of course let you know as soon as we become aware of timelines). The outcome of the original consultation can be found here. This is not an approach that the CLC supported because of the risk of dual regulation and increased burdens on practices.

HM Treasury is currently consulting on the powers and duties of the FCA when they do finally take over all AML supervision. This consultation will run until 24 December 2025 and the CLC considers, given the content of the consultation, that it is crucial for CLC practices to consider this and make their voices heard. Some of the proposals will be of acute interest to CLC practices such as how the FCA will pay for the supervision of AML which, it is proposed, should be done through charging new fees to practices. The new consultation can be accessed here.

The CLC will respond to this consultation and this response will be published on our website in due course.

The Treasury is holding roundtable discussions for the legal sector as follows:

• Legal sector:
  • 3 December, 11:00–12:30              https://www.eventbrite.co.uk/e/legal-sector-roundtable-consultation-on-the-fcas-powers-and-duties-tickets-1967627050475?aff=ebdssbdestsearch&keep_tld=1
  • 11 December, 11:00–12:30              https://www.eventbrite.co.uk/e/legal-sector-roundtable-consultation-on-the-fcas-powers-and-duties-tickets-1967649556792?aff=ebdssbdestsearch&keep_tld=1

We strongly encourage CLC lawyers to take part in these roundtable discussions and share your views about the government’s proposals. It is important that the UK has an effective and proportionate regime in place and that lawyers are not unduly burdened by it as they work to deliver services to their clients.

If you have any questions about the above please contact the CLC’s dedicated AML inbox: aml@clc-uk.org