The reform may not affect your supervisor. It could still raise important questions about your operational readiness.
The FCA has announced plans to become the anti-money laundering (AML) supervisor for legal service providers, accountancy service providers and trust and company service providers currently supervised by professional body supervisors or HMRC. The proposed changes are expected to be implemented gradually from late 2028, subject to legislation and further planning. Firms already supervised by the FCA under the Money Laundering Regulations will not be affected by the change in supervisory responsibility.
For many financial services firms, that might suggest the announcement has limited relevance.
We think there is a broader operational question worth considering.
Financial crime expectations continue to evolve
While the reform focuses on who supervises certain sectors, it also reflects a wider emphasis on consistency, accountability and effective oversight across the UK’s AML framework. The FCA has said its approach will be risk-based, targeted and proportionate.
For firms, the challenge is rarely understanding what good looks like.
The challenge is delivering it consistently at scale.
Financial crime teams are operating in an environment where customer volumes fluctuate, regulatory expectations continue to evolve, and experienced specialists remain difficult to recruit and retain. As a result, many organisations are balancing day-to-day operational demands with ongoing transformation activity, remediation programmes and assurance requirements.
The question is no longer simply whether controls exist.
It is whether firms can consistently demonstrate that those controls are operating effectively across people, processes and technology.
Operational resilience matters as much as framework design
Strong financial crime frameworks depend on strong operational delivery.
Even well-designed policies and controls can become ineffective if teams are under-resourced, backlogs emerge, quality assurance becomes inconsistent or specialist expertise is unavailable when required.
This is particularly relevant in areas such as:
- Transaction monitoring and alert management
- Enhanced due diligence and customer risk assessments
- KYC remediation programmes
- Financial crime change and transformation initiatives
- Skilled person reviews and regulatory remediation
- Quality assurance and control testing
In each case, firms need sufficient capability and capacity to maintain standards while responding to changing business and regulatory demands.
The capability challenge facing firms
Many firms have invested heavily in technology and controls over recent years. However, people remain central to effective financial crime management.
Experienced investigators, analysts, quality assurance specialists, programme managers and subject matter experts continue to play a critical role in ensuring that financial crime frameworks operate as intended.
When demand increases unexpectedly, firms often face difficult choices:
- Increase permanent headcount
- Divert existing resources from other priorities
- Accept slower delivery times
- Bring in specialist support
The most effective approach will depend on the firm’s circumstances, but maintaining access to specialist capability is increasingly becoming a key component of operational resilience.
Questions firms should be asking
The FCA’s announcement does not require immediate action from firms already supervised by the regulator.
However, it does provide a useful opportunity to consider:
- Could we demonstrate that our financial crime controls are operating effectively today?
- Do we have sufficient specialist capability to respond to increased demand?
- How quickly could we scale our financial crime operations if required?
- Are our quality assurance and oversight arrangements providing meaningful assurance?
- Do we have access to the expertise needed to support change, remediation or regulatory engagement?
The FCA’s AML reform serves as a timely reminder that effective financial crime management depends not only on frameworks and policies, but also on the people and operational capability needed to make them work in practice.
How Momenta can help
Momenta supports financial services organisations with specialist financial crime capability across advisory, transformation and operational delivery programmes.
Whether firms need experienced practitioners to support remediation activity, strengthen operational teams, deliver change initiatives or provide specialist expertise, access to the right capability can help maintain control effectiveness while responding to evolving regulatory and business demands.
