State of Financial Crime 2023 Report

FCA Proposes Updates to OPBAS Sourcebook

Regulators & Key Institutions Latest News

The Financial Conduct Authority (FCA) has published a consultation paper outlining proposed changes to the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) sourcebook to improve how professional body supervisors (PBSs) reduce money laundering in the sectors they oversee.

The updates are part of the FCA’s commitment to improving the consistency and effectiveness of anti-money laundering (AML) supervision, as highlighted in the agency’s Business Plan 2022/23

The consultation period for these changes opened on August 11 and will close on September 29. Feedback on the proposed changes can be submitted to the FCA through an online response form. The FCA aims to publish the revised sourcebook at the end of 2022 or early 2023. 

Proposed changes 

The consultation paper notes that the key to effectiveness is for PBSs to clearly understand the outcomes they seek to achieve through their supervisory activity. To facilitate this and provide guidance on assessing and measuring their supervisory activity, the following changes to the OPBAS sourcebook have been proposed:

  • A new chapter that explains OPBAS’s approach to supervision
  • More detailed guidance about expectations  
  • Set out expectations on the oversight of low‑risk firms
  • Examples of the outcomes expected to be achieved by PBSs  
  • More and expanded examples of practices considered more, and less, effective in achieving outcomes 
  • Case studies demonstrating elements of effective/ineffective supervision
  • More robust expectations for supervisory activity in PBS information and intelligence sharing
  • Clarify that PBSs are expected to consider and meet the training needs of staff based on their different roles and to ensure that they are assessing whether the training provided is effective

UK AML supervisory framework

In 2018, the government established OPBAS to strengthen the UK’s AML supervisory framework and address inconsistencies in supervision. OPBAS’s objectives are to reduce the threat of money laundering and terrorist financing by: 

  • Facilitating collaboration and information and intelligence sharing between PBSs, statutory supervisors, and law enforcement agencies
  • Ensuring a robust and consistently high standard of supervision by PBSs 

The UK’s National Risk Assessment (NRA) of money laundering and terrorist financing 2020 estimated that serious and organized crime costs the UK economy £37 billion annually. Furthermore, the NRA identified that the risk of money laundering through the accountancy and legal sectors remains high. The 25 PBSs that OPBAS supervises are the first supervisory line of defense against that risk, and the FCA has worked with PBSs since 2018 to monitor supervisory standards.

The PBSs supervised by the FCA should read this consultation as it sets out changes to the guidance on meeting supervisory obligations under the Money Laundering Regulations 2017


A Spotlight on Financial Crime

Stay on top of regional trends and novel criminal techniques so you can protect your business from financial crime.

Download now


Originally published August 18, 2022, updated August 22, 2022

Disclaimer: This is for general information only. The information presented does not constitute legal advice. ComplyAdvantage accepts no responsibility for any information contained herein and disclaims and excludes any liability in respect of the contents or for action taken based on this information.

Copyright © 2023 IVXS UK Limited (trading as ComplyAdvantage).