The Office for Professional Body Anti-Money Laundering Supervision (OPBAS) has published its 2024/25 supervisory report, and the findings should concern any firm in the legal or accountancy sectors: while baseline compliance is adequate, effectiveness is inconsistent, and some poor practice persists despite years of regulatory focus.
With the FCA preparing to assume direct supervision of professional services and HMRC issuing hundreds of penalties—including fines up to £104,000—firms can no longer rely on manual processes and assisted compliance approaches. The message is clear: robust, technology-enabled AML systems are essential.
Between April and September 2025, HMRC issued 336 penalty notices for Money Laundering Regulations breaches:
These aren't theoretical compliance risks, they're actual enforcement actions with real financial consequences.
OPBAS's assessment of 6 Professional Body Supervisors (PBSs) revealed concerning patterns:
Common breaches that continue to plague supervised firms:
These aren't new issues. OPBAS notes these failures "call into question the consistency and effectiveness of PBS supervision" and suggests "continued failures" despite regulatory attention.
The report identifies specific weaknesses across the legal and accountancy sectors:
1. Overly member-centric supervision
OPBAS found that some PBSs "take an overly member-centric approach or assisted compliance view" that "hinders robust AML supervision."
In practice, this means PBSs provide templated documents for members to address breaches (for example, providing a risk assessment template when a firm has failed to conduct one as required). While support is appropriate, it shouldn't come "at the cost of holding members to account for material non-compliance."
2. Weak enforcement
PBSs "continue to perform poorly in their enforcement approach relative to other Sourcebook areas." OPBAS is concerned that some aren't taking "consistent, proportionate and sufficiently dissuasive disciplinary measures."
Examples of less effective practice include:
3. Inadequate use of technology
While OPBAS supports AI and technology use to understand risk better, implementation varies widely. Some smaller PBSs "could have made more effective use of the tools available to them."
The report notes concerns about third-party AML software: "Different views were expressed on the quality of the third-party provided AML software and outcomes achieved. We're unclear on how assurance is obtained by the supervised population or PBSs in these circumstances."
4. Insufficient ongoing monitoring
OPBAS found that some PBSs rely too heavily on "member self-certification, without associated and risk-sensitive proportionate assurance activity."
Static checks at onboarding aren't sufficient—customer risk profiles change, beneficial owners change, and business activities evolve.
The scale of AML supervision in professional services is substantial:
With only 213 FTE staff dedicated to AML supervision across all PBSs (combined annual spend £15m), the coverage challenge is immense.
OPBAS's data shows that even with improvements, manual approaches struggle:
On-site visits and desk-based reviews:
While OPBAS notes this "compares favourably to other AML supervisors," it still means nearly 90% of firms receive no onsite inspection in a given year.
More concerning: onsite visits in the accountancy sector have not returned to pre-pandemic levels. The 2023/24 figure was slightly lower than 2022/23.
The report welcomes that "subject to legislation, the FCA will become the single Anti-Money Laundering/Counter Terrorist Financing (AML/CTF) supervisor for selected professional services."
This transition will bring:
The FCA's supervisory model emphasises outcomes over box-ticking—exactly what OPBAS has been pushing for.
Manual compliance processes can't deliver what regulators now expect. Here's why technology is essential:
1. Identity verification at scale
With 41,400 firms under supervision and millions of client interactions, manual document checks don't scale. Biometric verification, document forensics, and multi-source identity triangulation catch risks visual inspection misses—in seconds, not days.
2. Beneficial ownership transparency
OPBAS highlighted that shell companies and complex ownership structures are key money laundering risks. Automated beneficial ownership identification traces through multiple corporate layers to reveal ultimate controllers—something manual searches struggle with.
3. Real-time sanctions screening
OPBAS found gaps in how firms screen against sanctions lists. Automated screening against 1,100+ global sanctions and PEP lists, updated every 24 hours (not annually), ensures firms catch newly designated entities immediately.
4. Ongoing monitoring
The report criticises reliance on static onboarding checks. Continuous monitoring throughout client relationships flags changes in risk profiles, new sanctions designations, and evolving business activities automatically.
5. Audit-ready compliance
With enforcement increasing and the FCA taking over, firms need documented proof of robust due diligence. Technology provides timestamped, cryptographically secure records for every check, evidence that manual processes rarely capture comprehensively.
6. Consistent decision-making
OPBAS noted that some PBSs would benefit from enhanced guidance for staff "to support consistency in decision-making." Automated risk assessment removes human inconsistency while flagging high-risk cases for expert review.
SmartSearch provides the technology infrastructure professional services firms need to meet OPBAS's effectiveness standards:
Instant identity verification
Beneficial ownership identification
Real-time AML screening
Ongoing monitoring
Audit-ready records
While concerns about AI often focus on risks, OPBAS takes a balanced view: "We support PBSs in their use of technology and artificial intelligence to better understand risk."
The guidance is practical: AI must be "robustly tested" and use "relevant and accurate data sources," with systems that are "understood, documented and auditable."
This is the responsible approach, not avoiding AI, but deploying it thoughtfully with proper oversight.
AI's role in better AML compliance:
The productivity gains enable firms to achieve OPBAS's 10.2% coverage benchmark—or exceed it—without proportionally increasing headcount.
With the FCA transition approaching and enforcement increasing, professional services firms should:
1. Audit current AML processes
2. Assess technology gaps
3. Invest in automated compliance
4. Prepare for FCA supervision
The OPBAS 2024/25 report makes clear that baseline compliance isn't enough—effectiveness matters, and persistent failures will face consequences.
With HMRC issuing fines up to £104,000, the FCA preparing to assume supervision, and technology enabling compliance that manual processes can't match, the path forward is obvious.
Firms need robust, automated AML systems that deliver:
SmartSearch provides exactly this—compliance infrastructure purpose-built for the professional services sector's unique challenges.
The question isn't whether to modernise AML compliance. It's whether to do it now, while you control the timeline, or wait until the FCA takes over supervision and expectations increase further.