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The UK is approaching the most significant change to professional services oversight since the introduction of the 2007 Money Laundering Regulations.
As per HMT’s recent policy statement, law firms, accountancy practices, trust and company service providers, and corporate-service firms are preparing for direct supervision by the UK's Financial Conduct Authority (FCA) for Anti-Money Laundering (AML) purposes, shifting oversight away from their current professional bodies.
While some fear that bringing anti-money laundering supervision under the remit of the FCA will increase business costs, the consolidation aligns with the UK’s broader intent to tighten its economic framework, raise supervisory standards, and position professional services within the same expectations applied to regulated financial institutions.
Drawing on insights from our current hiring projects in regulated sectors, we outline below how this shift is expected to unfold and what it means for the skills firms will need to develop.
What the Transition Will Look Like
The move to FCA supervision introduces a different philosophy of oversight. The FCA’s approach is data-led, interventionist, expectation-heavy, and focused on measurable outcomes rather than stated intentions (hence the growing value of Statement of Work engagements).
Professional-services firms that have operated for years under professional-body supervision will likely experience a marked shift in scrutiny, accountability and the pace at which issues must be addressed.
Firms should expect more structured reporting, more formal governance arrangements, and clearer lines of individual responsibility. The regulator will also look closely at how well firms understand their exposure to financial crime risk, how they monitor high-risk clients, and how effectively they escalate and remediate concerns.
Key Milestones
The government is yet to announce specific dates, but the consultation process is currently underway, with the deadline for responses set for December 24th.
Once announced, the process will move into legislation and rule-building, a detailed phase that, given the scale of the reform, is expected to run across 2025 and 2026.
When this groundwork is complete, firms can expect a transitional period followed by phased implementation from 2027 onwards, with higher-risk sectors likely to enter scope first and full maturity of the regime closer to the end of the decade.
What This Means for Firms
Perhaps unsurprisingly, the early stages of supervision will place particular weight on operational resilience within financial crime and risk functions.
Firms will find that their existing infrastructures are designed for professional body oversight rather than the level of evidential precision the FCA expects.
Senior leadership will also feel the weight of heavier expectations, especially those who rely on informal influence or diffused responsibility.
A Change in Workload Patterns
Enhanced monitoring, periodic reviews and data-driven assessments will require sustained capacity rather than ad-hoc effort during audits or inspections.
We expect this to influence how teams are structured, including which skills are required to support day-to-day activity.
Client acceptance and ongoing due diligence will come under closer examination. High-risk relationships will need deeper scrutiny, and firms may need to adjust their approach to onboarding, documentation and escalation to meet the standard expected under public regulation.
These pressures are manageable with preparation, but firms that wait for final rules to be published may find themselves reacting to issues rather than shaping their response in advance.
Talent Implications
FCA supervision will introduce new expectations around capability, capacity and structure.
We expect many professional-services firms to expand teams that have previously been small or highly decentralised, particularly across financial crime, risk, data and assurance.
Roles covering AML, sanctions, monitoring, investigations and thematic analysis are expected to see increased demand, alongside governance and reporting functions that can evidence how decisions are made and implemented.
These areas are already stretched across financial services, so competition for experienced candidates may rise once the regime begins to take shape.
We also expect firms to look for broader operational support. FCA supervision relies on clear documentation, strengthened quality assurance and consistent execution.
This is likely to create demand for people who can build and maintain frameworks, manage reviews and ensure that information flows reliably across teams.
Leadership capability should be an early priority. The FCA typically expects individuals with the authority and experience to take ownership of key areas, interpret risk, challenge decisions and guide operational change.
Some firms may introduce new senior roles or elevate existing ones to meet this expectation.
As the regime evolves, we expect organisations to move from initial uplift to sustained capability building. The period between 2025 and 2028 is likely to be particularly active for hiring as firms adjust their structures in line with the emerging supervisory model.
Looking Ahead
The firms that begin preparing now will move through the transition with greater clarity and control. The regulatory bar is rising, and the organisations that anticipate what this means for their structures, processes and people will be best positioned for the new era of supervision.
Leaders across professional services can take practical steps ahead of the formal announcement in 2025.
- Review existing AML, sanctions and governance structures
- Map capabilities against likely FCA expectations
- Identify future accountability roles and reporting lines
- Plan workforce needs across 2025 to 2028
- Build early visibility of skills gaps, especially across financial crime and governance
If you are reviewing how your organisation will adapt to FCA supervision, our team can provide a clear view of the emerging talent requirements across risk, financial crime and governance. For a confidential conversation, please send us a message via our website: https://www.broadgatesearch.com/contact-us.