ACCA is a Professional Body Supervisor (PBS) for anti-money laundering (AML) in the UK. We welcome the opportunity to comment on proposals for the key duties, powers, and accountability mechanisms that the Financial Conduct Authority (FCA) will need to be an effective AML supervisor of professional services businesses and legislative changes to enact these. Our response to this consultation has been informed by input obtained from our supervised population and discussions with other accountancy PBSs.

ACCA fully supports the development of an effective UK AML supervisory regime that provides confidence in the UK as a safe, transparent and compliant jurisdiction to conduct business in. We believe that a robust and effective framework to tackle economic crime will help improve and facilitate further commercial activity for businesses in the UK.

The adoption of a Single Professional Services Supervisor (SPSS) marks a significant change in the regulatory landscape affecting ACCA and all other accountancy service providers. We believe there are a number of risks to the SPSS model, including increased economic crime and a greater regulatory burden. Whilst ACCA does not agree that transferring AML responsibilities to the FCA is the right approach, we are proactively working with HMT to implement this policy decision to best effect.

ACCA is generally supportive of the proposed duties, powers, and accountability mechanisms. For example, we welcome the proposals relating to a register of all professional services firms, fit and proper tests, access to SAR, extended information gathering and inspection powers, and an information-sharing regime.

However, we have identified some areas of concern, and these are highlighted in our responses to the questions raised where appropriate. In particular, we have concerns that:

• Duties, powers, and accountability mechanisms will not be practical or proportionate to the risk posed by accountancy firms and will impose unnecessary bureaucracy and costs. This will particularly impact sole practitioners and small practices who will likely see a significant rise in fees. Under the SPSS model, ACCA firms will face the prospect of dual supervision and dual fees for AML supervision and their professional body.
• Length of time it will take to implement a single AML supervisor could cause considerable disruption in supervision. In a challenging economic climate, these increased costs to businesses, large and small, cannot be justified.
• Proposals will create a greater regulatory burden which could lead to increased economic crime and undermine growth in the accountancy sector.
• In our opinion, a number of the proposals require further engagement and discussion to identify and address any ambiguities and unintended consequences. Therefore, we would encourage full, timely and open dialogue with the PBSs and the sectors as the FCA develops its supervisory framework and during the transition period.

To read the response in full, please download the consultation document found on this page.