Dear CEO | Release Date: 20th March 2023

To read a longer summary of this Dear CEO letter, click here.

To access the original FCA document, click here.

Short Summary

The Office for Professional Body Anti-Money Laundering Supervision (OPBAS) has issued an updated supervisory note addressing the annual Regulation 46A money laundering reports required under the Money Laundering Regulations 2017 (MLRs). These reports, initiated in November 2021, are essential for Professional Body Supervisors (PBSs) to document their anti-money laundering and counter-terrorist financing (AML/CTF) supervisory activities.

Following feedback from both OPBAS and HM Treasury (HMT), the recent update clarifies the expectations for these reports, emphasising the importance of effectively demonstrating supervisory effectiveness. While compliance with Regulation 46A is mandatory, OPBAS encourages PBSs to go beyond mere compliance to enhance the effectiveness of their AML/CTF efforts.

The updated guidance suggests that PBSs include more detailed information about their supervisory activities, especially those not directly covered in the update note, such as sanctions-related work. The reports serve not only as a compliance tool but also as a means for PBSs to illustrate their role and progress in improving AML/CTF supervision within their sectors.

The upcoming reports for the period from April 6, 2021, to April 5, 2022, are due by November 1, 2022. PBSs are urged to consider both the mandatory elements and the recommended practices to enhance the overall quality and effectiveness of their reports. For any inquiries, PBSs are advised to contact their usual OPBAS supervisor.