The Financial Conduct Authority says it will begin taking responsibility for the anti-money laundering supervision of about 60,000 legal, accountancy and trust or company-service providers at the end of 2028. Its case for readiness includes a striking figure: the regulator’s intelligence systems can process more than 56 million records a day and flag high-risk firms earlier.
That is evidence of computing capacity, not yet of supervisory effectiveness.
The FCA’s 17 September speech does not identify the record types, say how many are duplicates, disclose the number of alerts produced, or show how often a flag becomes an inspection, remediation order or enforcement case. It says the FCA is exploring the potential for agentic supervision while keeping human judgement decisive. It does not say that an agentic system is deployed, which decisions it may recommend, or whether it could execute any of them.
Those omissions matter because the transfer is not simply a database migration. It is an operating test of whether centralisation can turn information into faster, more consistent action.
Three numbers describe the present system
The supervisor counts can sound contradictory because official sources use different frames. The UK’s latest Treasury supervision report refers to 25 UK AML supervisors in total: the FCA, HM Revenue and Customs, the Gambling Commission and 22 legal and accountancy professional body supervisors.
The government’s 2025 reform response counts 23 supervisors of professional-services firms: those 22 professional body supervisors plus HMRC. The current OPBAS landing page uses a separate 25-body administrative count, saying it supervises 25 professional body supervisors. Neither source reconciles the additional three bodies in OPBAS’s wording with Treasury’s 22-body count, so they should not be treated as the same measure.
The new remit is different again. It moves firms currently overseen by those professional bodies, together with accountancy and trust or company-service providers supervised by HMRC, under the FCA for AML purposes. Their professional conduct regulators will remain in place. That distinction creates a continuing need to share information and co-ordinate cases even after the headline consolidation.
The 2028 date is a target, not a statutory guarantee
The legal machinery is moving. The Financial Services and Markets Bill completed its Lords stages and received its first reading in the Commons on 15 September. A date for Commons second reading had not been announced by 18 September.
The bill expands the Treasury’s power to provide for co-operation and information sharing between AML supervisors and other regulators. The government’s June 2026 consultation response says the arrangements will be taken forward through primary legislation and detailed through secondary legislation amending the Money Laundering Regulations during implementation.
Important operating choices therefore remain outside the current headline. The FCA’s ongoing supervisory costs are intended to be recovered from firms through fees, with a separate FCA consultation still to set the structure. The Treasury and FCA are also still developing the transition and implementation plans. The FCA’s end-2028 statement is the clearest timetable yet, but Parliament has not enacted a fixed handover date.
The baseline is measurable, but incomplete
The existing system provides a starting scorecard. In 2024/25, the 22 professional body supervisors had 229.65 full-time equivalent staff dedicated to AML supervision and spent an estimated £22 million. They conducted 3,255 desk-based reviews and 1,632 onsite visits, putting about 12% of their supervised population through direct supervisory activity, up from 10% a year earlier.
Among assessments completed in the year, accountancy supervisors classified 17% of firms as non-compliant and legal supervisors classified 26% that way. The bodies issued 338 AML fines worth more than £2 million, cancelled 33 memberships for AML reasons, and recorded 697 formal and 915 informal actions.
Those figures are not a complete performance measure. Supervisors use different methods and risk classifications. The latest OPBAS assessment also found that some bodies gave firms repeated opportunities or excessive time to correct failures before referring cases for enforcement. Yet neither the Treasury report nor the FCA’s new speech supplies a comparable system-wide measure for the time from first concern to closure, the proportion of remediation completed by deadline, or the share of sanctions upheld on challenge.
Centralisation should make those gaps easier to close. It should not erase the baseline.
Fifty-six million records need a conversion rate
A useful technology metric would connect inputs to decisions. For every alerting system, the FCA could publish the number of unique records ingested, alerts generated, alerts closed as false positives, firms escalated, supervisory interventions opened and cases passed to enforcement. It could then report median and upper-quartile time from flag to action.
Agentic supervision needs an equally clear boundary. A system that assembles evidence for a human is different from one that selects a firm for inspection, drafts a statutory notice or recommends a penalty. Each step raises different questions about audit trails, legal privilege, data quality, human review and appeal. Saying that human judgement remains decisive does not reveal where that judgement enters the process.
Before the transfer, the FCA and Treasury should publish a scorecard covering inspection rates by sector and risk band, alert-to-intervention conversion, remediation timeliness, repeat non-compliance, case duration, sanctions and successful appeals. The 2024/25 figures offer the comparison point.
One regulator can still inherit fragmented data, slow cases and inconsistent enforcement. If the FCA reports only how much information it processes, the reform will have changed the supervising logo. If it shows that credible cases are found earlier, resolved faster and followed by proportionate sanctions, the 60,000-firm transfer will have proved its point.
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