OPBAS 2024/25 Report: What It Means for Accountants

If your firm is supervised for anti-money laundering (AML) by a professional body, the body that checks the checker is the Office for Professional Body Anti-Money Laundering Supervision (OPBAS), which is part of the Financial Conduct Authority (FCA). In March 2026 OPBAS published "Progress and themes from OPBAS's 2024/25 supervisory work", its report on how the legal and accountancy professional body supervisors (PBSs) are performing. It is not guidance for firms, but it tells you what supervisors have been told to do better, and therefore what firms should expect. This guide summarises the main findings and what to take from them. It is general information, not legal advice.

The report matters now because the FCA is due to take over AML supervision of the accountancy and legal sectors. For that background, see our guide to the FCA as single AML supervisor.

Who OPBAS oversees and how it assesses them

According to the report, OPBAS oversees 22 PBSs plus three bodies with delegated regulatory functions, covering the accountancy and legal sectors and more than 41,400 firms and practitioners. It assessed six PBSs between the fourth quarter of 2024 and the first quarter of 2026, using its updated sourcebook and a four-point scale that runs from "Effective" to "Ineffective". The areas assessed were governance, the risk-based approach, supervision, intelligence and information sharing, information and guidance to members, staff competence and training, enforcement, and record keeping and quality assurance.

In its news story of 3 March 2026, the FCA said that professional services AML supervisors are more effective than at any time since OPBAS was founded in 2018, but that improvements are still needed.

The headline findings

The report says most ratings were "Largely Effective" or better, with record keeping the strongest area. Enforcement and supervision were the weakest, and several PBSs were rated "Partially Effective" on them. OPBAS says it is "less assured" about supervision and enforcement than about the other areas. Governance was described as relatively mature, although management information needed to show more clearly how it is used to challenge a supervisor's AML strategy.

What the report says about supervision

The findings that matter most to firms are about the breaches supervisors keep finding. The report says common breaches persist, including inadequate policies, customer due diligence, client risk assessments and firm-wide risk assessments. It also makes several points about how supervisors work:

• Some PBSs took an "overly member-centric" or "assisted compliance" approach, and the report cites templated documents handed to members to fix a missing risk assessment as an extreme example.
• Remediation timelines were often too long and deadlines were not always followed up.
• Some PBSs were slow to include emerging risks such as proliferation financing in their risk assessments.
• OPBAS warned about over-reliance on artificial intelligence risk models, giving an example in which every new firm was given a default medium rating, which could delay reviews by up to two years.
• Reliance on third-party AML software is a concern, because, the report notes, the Money Laundering Regulations make clear that risk cannot be outsourced.

Enforcement is the weakest link

The report calls enforcement the weakest area relative to the other parts of the sourcebook. It says some PBSs relied too heavily on assisted compliance, gave repeated chances before taking enforcement action, and allowed lengthy compliance plans. Enforcement decisions were published but were hard to find on some PBS websites, which weakens their deterrent effect, and some PBSs struggle to recover fines.

The report includes points specific to accountancy. It says accountancy PBSs have lower average enforcement effectiveness scores than legal PBSs, and that total fines in the two sectors were similar but the average accountancy fine was more than six times lower. It gives case studies in which an accountancy PBS was not reviewing members' suspicious activity reports, and another sampled only about 1% of client risk assessments after a member failed to provide proof of due diligence. It also says a smaller accountancy PBS had not used a thematic review to understand the risks from trust and company service provider activity in its population.

On OPBAS's own powers, the report says it issued its first public censure in 2025 and used its directions power once in the cycle. The FCA's news story names the Institute of Certified Bookkeepers as the body censured for failing to meet its requirements under the Money Laundering Regulations.

How much supervision actually happens

The report gives figures of 2,663 desk-based reviews and 1,557 onsite visits across both sectors, equivalent to 10.2% population coverage, although it does not state the period in the paragraph we reviewed, so treat these as indicative. It says onsite visits have not returned to pre-pandemic levels, and that accountancy visits dipped slightly in 2023/24. Put simply, most firms are not reviewed in any one year, but supervisors are being pushed to review faster and act earlier when they find problems.

Other work: SARs, TCSPs and professional enablers

The report also describes OPBAS's wider projects. On suspicious activity reports, it says OPBAS reviewed how supervisors responded to HM Treasury's 2023-24 supervision report and assessed SAR quality for two legal and two accountancy PBSs, finding the samples to be of good quality, with follow-up letters sent in April and September 2025. On trust and company service providers, it says a September 2025 stakeholder event found better collaboration, enhanced guidance to supervised populations and additional data collected from them, and that OPBAS will keep coordinating cross-sector work, including on the raised terrorist financing risk for these providers in the National Risk Assessment 2025 and the then-proposed rules on selling off-the-shelf companies. It also says OPBAS led actions under the Professional Enablers Strategy, whose remit ended in April 2026.

The transition to the FCA

The report says that, subject to legislation, the FCA will become the single AML supervisor for selected professional services. It says PBSs must continue to meet their Money Laundering Regulations obligations until they are formally removed, and describes 2026/27 as the first period of significant transition. It lists OPBAS's priorities for that year as managing an orderly transition and supporting the FCA, strengthening supervision and coordination, continuing its focus on professional enablers, information sharing and third-party AML providers, project work on terrorist finance risk, deciding the future of the regional intelligence working groups, and guiding PBSs on the regulation changes that affect due diligence on shelf companies. For firms, nothing changes in who supervises you today, but supervisors are being told to tighten up while the transition is prepared.

What accountancy firms should take from it

These are our suggestions, not requirements in the report:

• Expect less patience. The report criticises repeated chances and long compliance plans, so assume a missed deadline or repeated breach will be treated more seriously.
• Get the basics right first. Policies, customer due diligence, client risk assessments and your firm-wide risk assessment are the breaches named. Make sure each is documented and current.
• Do not outsource judgement. If you use screening or onboarding software, keep evidence that you understand its output and that a person owns the decision.
• Keep reporting records. Your MLRO should be able to show how internal reports and SARs were considered, as set out in our guide to the MLRO's role.
• Review your trust and company service exposure. The report treats this as a continuing concern, so check whether any of your work counts and that it is covered by your risk assessment.
• Know your supervisor. HMRC supervises many accountancy firms directly rather than through a professional body, and we cover its approach in our guide to HMRC AML enforcement.

Frequently asked questions

Does OPBAS supervise my firm directly?

No. OPBAS oversees the professional body supervisors, not individual firms. Your firm is supervised by its professional body or by HMRC, whichever is your AML supervisor.

Is the report a set of rules for firms?

No. It reports on how supervisors are performing. It is useful because it shows what supervisors have been told to improve and which breaches they keep finding.

Will the FCA change who supervises me straight away?

The report says the change is subject to legislation and that PBSs must keep meeting their obligations until they are formally removed. Check your supervisor's announcements for timing.