Accountancy Practices
The FCA is coming. Are you ready for what that means?
The FCA is confirmed as the incoming AML supervisor for accountancy practices. FCA supervisory standards, investigative approach and fine levels are materially different from professional body supervision. Most practices are not yet prepared for what that means in practice.
The question is whether your MLCO and MLRO can produce the same density of evidence the FCA already expects from solo-regulated firms — not whether your template pack looks compliant on the shelf.
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The regulatory landscape
Today, most practices are supervised by their professional body for AML — with OPBAS coordination and HMRC overlay where relevant. That world rewarded proportionate documentation. The incoming FCA posture rewards provable operational reality: risk assessment specificity, CDD reasoning, SAR logs, and governance challenge that can be evidenced under interview conditions.
ACSP registration (from spring 2026) adds a Companies House verification layer with personal accountability for the named Compliance Principal. Verification decisions are not administrative ticks — they are evidence problems when challenged.
Tax authority and economic crime priorities continue to emphasise enablers, gatekeepers and poor gatekeeping records. Accountancy practices sit at the intersection — which means file quality is political as well as technical.
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What regulators look for
Inspectors test whether the firm-wide risk assessment reflects actual client types, services, jurisdictions and delivery models — not a boilerplate adapted once a year. Template risk assessments remain one of the most common findings across professional body supervision; the FCA will treat them harder.
SAR decision logs must capture decisions not to report with MLRO reasoning and dates. On inspection day, partial logs are treated as absent logs.
Board-level MLCO authority is tested in practice: can the MLCO direct staff, escalate to the partners, and evidence that escalation? A junior "compliance manager" without authority is a structural finding waiting to happen.
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What Evidentia gives you
MLCO / MLRO evidence base
Firm-wide risk assessment reviews, CDD decisions, SAR determinations and ACSP verification records — sealed at creation, retrievable in seconds.
FCA-density documentation
Structured records that mirror how FCA supervisors read files — chronology, reasoning, and accountability — not retrospective narrative.
Partner challenge on record
When partners override risk or push borderline clients, the challenge-and-outcome trail is recorded — the evidence pattern FCA enforcement expects to see in serious cases.
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The evidence gap
Most practices we speak to run reputable client acceptance and monitoring. The weakness is evidentiary: reasoning sits in partner heads, emails and informal notes — not in a tamper-evident system of record.
When supervision transitions, the FCA will not wait for you to "get organised." The first supervisory cycle may define how the firm is categorised for years.
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Key enforcement facts
ACSP registration became compulsory from spring 2026 — a new verification and accountability layer for Compliance Principals.
FCA incoming AML supervision will apply higher evidential standards than template-led professional body inspections.
SAR logs without decisions-not-to-report are a recurring enforcement and inspection trigger across AML regimes.
Find out whether your current approach would withstand scrutiny.
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