In its response to HM Treasury’s AML supervisory consultation, submitted 28 September 2023, ICAEW explained its preferred option was for the proposed OPBAS+ model, which would enhance the powers of OPBAS and increase the effectiveness of professional body supervision (PBS).
ICAEW said this would preserve and build on the significant investment already made in OPBAS, maintain the UK’s alignment with AML work in Europe, and reduce the risk of uncertainty posed by the upheaval which would be caused by the other options proposed. OPBAS+ was the option that could be implemented swiftly, building on the current system and requiring only minor changes to legislation.
The other proposals – consolidation of professional bodies; a single supervisor for professional services; and a single regulator – would bring with them a number of risks which could allow criminals to operate and do damage to the economy.
ICAEW said that the other options would risk gaps in intelligence from the disruption in already-existing intelligence-sharing relationships.
There would also be a reduction in awareness and competency of AML risk as professional bodies would lose their incentive for creating educational material and running initiatives to boost knowledge, ICAEW said.
Additionally, ICAEW raised fears that a new regulator could be understaffed if employees at the existing bodies did not move across. In this case it would lack the expertise to operate effectively, which would weaken AML supervision.
Michelle Giddings, ICAEW’s Head of AML and Operations, said:
“We take our role as an AML supervisor very seriously, but acknowledge there are areas where the system could benefit from reform.
“It’s vital that professional bodies like ICAEW continue to play a role in AML supervision. We gather a wealth of intelligence through our relationships with the firms we supervise, and removing professional bodies from AML supervision risks losing this valuable intelligence.
“In our view the OPBAS+ model will deliver the most feasible and effective way to improve supervision by building on what works. We are concerned that the other options proposed would weaken AML regulation, and risk leaving the door open for criminals to do business in the UK and cause wider damage to the economy.”
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