HMRC, FCA and AML Supervision: What UK Firms Need to Know
In brief: HMRC, FCA, and professional body supervisors do not all supervise the same firms, but they all expect regulated businesses to understand their AML risks, apply CDD, keep records, and evidence decisions.
Key points
- HMRC supervises many accountancy service providers and trust or company service providers for AML.
- The FCA supervises financial services firms for financial crime and AML obligations.
- Some accountants and law firms are supervised by approved professional bodies rather than HMRC.
Who supervises AML compliance in the UK?
UK AML supervision depends on the type of business. HMRC supervises many accountancy service providers and trust or company service providers. The FCA supervises financial services firms. Some accountants and law firms are supervised by professional body supervisors.
The practical point for a firm is not memorising every regulator. It is knowing who supervises your business and keeping evidence that your AML controls work.
HMRC supervision
HMRC is an AML supervisor for several sectors, including many accountancy service providers. HMRC publishes registration and supervision guidance on GOV.UK, including money laundering supervision for accountancy service providers.
For an accountancy practice, HMRC may expect evidence of:
- Firm-wide risk assessment.
- Client risk assessments.
- CDD and beneficial ownership checks.
- PEP and sanctions screening where relevant.
- Policies, controls, and procedures.
- Staff training.
- Record keeping and review history.
- Internal reporting and escalation processes.
FCA supervision
The FCA supervises financial services firms and focuses heavily on financial crime systems and controls. FCA material on financial crime and AML is available at FCA: financial crime and FCA: money laundering and terrorist financing.
Even if a firm is not FCA-supervised, FCA expectations are useful context for strong controls: governance, risk assessment, monitoring, escalation, and senior accountability.
Professional body supervision
Some accountants and law firms are supervised by professional bodies. The exact supervisor affects registration, reporting, and inspection process, but the underlying evidence themes are similar: risk, CDD, controls, records, training, and escalation.
What to keep ready
| Evidence area | What a reviewer wants to see |
|---|---|
| Risk assessment | Current firm-wide and client-level risk records. |
| CDD | Identity, ownership, purpose, and verification evidence. |
| Screening | Results, false-positive decisions, and review notes. |
| Policies | Written controls that match the actual firm. |
| Training | Staff completion records and practical escalation guidance. |
| Review | Dates, triggers, updates, and management sign-off. |
Common mistake
The biggest mistake is producing policies but weak client files. Supervisors usually want to see whether the written procedure actually shows up in day-to-day evidence.
Official references
- HMRC accountancy service provider AML registration
- FCA financial crime
- FCA money laundering and terrorist financing
This guide is general information and is not legal advice.