OPBAS, the Office for Professional Body Anti Money Laundering Supervision, is a part of the Financial Conduct Authority that supervises the professional bodies which act as AML supervisors for accountants and lawyers. It does not inspect firms, but its findings and powers push bodies such as ICAEW, ACCA and AAT to review firms more rigorously, follow up remediation faster and use fines rather than advice where firms fall short.

What is OPBAS?

OPBAS was created by the Oversight of Professional Body Anti Money Laundering and Counter Terrorist Financing Supervision Regulations 2017, which came into force on 18 January 2018. It is housed within the FCA, funded by fees it charges the bodies it oversees, and accountable through the FCA to HM Treasury and Parliament. The FCA describes its two objectives as ensuring a robust and consistently high standard of supervision by the professional body supervisors (PBSs) and facilitating collaboration and information sharing between PBSs, statutory supervisors and law enforcement.

The standard OPBAS measures bodies against is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and its own OPBAS Sourcebook, which sets out how PBSs can meet their obligations in areas such as governance, the risk based approach, supervision, information sharing, guidance to members, staff training, enforcement and record keeping.

Which bodies does OPBAS oversee?

Under regulation 7 of the Money Laundering Regulations 2017, each professional body listed in Schedule 1 is the supervisory authority for its members, and HMRC supervises accountants and tax advisers who are not supervised by one of those bodies. Schedule 1 lists 22 bodies. The accountancy sector bodies on the FCA’s OPBAS list are:

  • Association of Accounting Technicians
  • Association of Chartered Certified Accountants
  • Association of International Accountants
  • Association of Taxation Technicians
  • Chartered Institute of Management Accountants
  • Chartered Institute of Taxation
  • Institute of Accountants and Bookkeepers
  • Institute of Certified Bookkeepers
  • Institute of Chartered Accountants in England and Wales
  • Institute of Chartered Accountants in Ireland
  • Institute of Chartered Accountants of Scotland
  • Institute of Financial Accountants
  • Insolvency Practitioners Association

The FCA says OPBAS does not supervise members of professional bodies, such as firms and accountants, does not supervise statutory supervisors such as HMRC, and does not look at body functions unrelated to AML supervision. A practice supervised by HMRC is therefore outside the OPBAS system entirely; see HMRC as AML supervisor. Wider professional regulation of the chartered bodies is overseen by the FRC, as explained in the FRC’s oversight of accountancy bodies.

What powers does OPBAS have?

The 2017 OPBAS Regulations give the FCA a set of escalating powers over a self regulatory organisation:

  • Information and skilled persons. Regulation 7 allows it to require information, and regulation 13 provides for a report by a skilled person.
  • Directions. Under regulation 14 it may give a written direction to remedy or prevent a failure to comply with a supervision requirement, requiring or prohibiting specified action.
  • Public censure. Regulation 16 allows it to publish a statement censuring a body that has failed to comply with a supervision requirement, an information requirement or a direction.
  • Removal. Regulation 17 allows it to recommend to the Treasury that a body be removed from Schedule 1, and the Treasury must take that recommendation into account.
  • Charges. Regulation 27 allows it to charge bodies to meet its reasonable expenses.

Removal from Schedule 1 is the most serious outcome for firms, because members would need a new AML supervisor. In its report on 2024/25 work, OPBAS said it used public censure against a PBS for the first time in 2025 and used directions once in the cycle.

What did OPBAS find in its latest report?

The report on OPBAS’s 2024/25 supervisory work, published in March 2026, covered assessments of 6 PBSs between the last quarter of 2024 and the first quarter of 2026, rated on a four point scale from effective to ineffective. Its headline was that baseline compliance is good and effectiveness is improving, but some poor practice persists. Points most relevant to practices:

  • Enforcement remains the weakest area. Some PBSs rely too much on “assisted compliance”, working with firms to fix failures instead of taking proportionate, dissuasive disciplinary action. OPBAS gave the example of an accountancy body that gave a firm multiple chances before making an enforcement referral.
  • Remediation is too slow. For most PBSs, file reviews showed remediation timelines that were too long or not followed up, with overreliance on members’ self certification.
  • Review samples were weak. Some PBSs relied on files chosen by the member rather than at random, and one accountancy body reviewed only about 1% of client risk assessments after finding missing customer due diligence.
  • The same breaches keep recurring. Citing HM Treasury’s 2023 to 2024 supervision report, OPBAS said firms are still reported for inadequately documented policies and procedures, customer due diligence failures, weak client risk assessments or records, and missing or inadequate firm wide risk assessments.
  • Templates are not a fix. OPBAS criticised supervisors that hand members templated documents to cure a breach such as a missing risk assessment required by regulation 18.

How do OPBAS findings affect the supervision a firm receives?

Because OPBAS judges supervisors on outcomes, its criticisms tend to reappear as changes in how the bodies treat firms. Based on the themes above, a practice should expect:

  • reviewers choosing files themselves, and asking for larger samples of client risk assessments and due diligence records;
  • shorter, firmer deadlines for remedial action, with evidence demanded rather than a signed declaration;
  • quicker referral to disciplinary processes, and more fines, for repeat or serious failings; see AML penalties for firms;
  • closer attention to the firm wide risk assessment, which OPBAS singles out as a continuing problem; and
  • more questions in annual returns about emerging risks such as cryptoassets and trust or company services.

The trend is visible in the data OPBAS published. For the accountancy sector it reported 201 AML fines and 48 membership cancellations in 2023/24, compared with 96 fines and 26 cancellations in 2017/18. Firms can also read their own supervisor’s annual report: regulation 46A of the Money Laundering Regulations requires each body to publish information about the measures it takes to monitor and enforce compliance. Our guide to AML supervisory reviews covers what a visit involves.

What happens to OPBAS under AML supervision reform?

OPBAS’s own report says that, subject to legislation, the FCA will become the single AML supervisor for selected professional services, and describes the FCA as the “supervisor in waiting”. OPBAS’s stated role in the meantime is to keep working with PBSs to support an orderly transition. The timetable and what it means for practices are covered in AML supervision reform and the FCA. Until any change takes effect, a firm’s supervisor remains its professional body or HMRC.

How might this look for a practice?

Illustration only. A sole practitioner supervised by a bookkeeping institute had a desk based review three years ago. The reviewer found an out of date firm wide risk assessment, accepted the practitioner’s written confirmation that it would be updated, and closed the file.

After OPBAS criticises that body for relying on self certification, the next review asks for the updated risk assessment itself, selects five client files at random, finds two without documented risk assessments and sets a 30 day deadline with a follow up check. When the follow up shows only partial progress, the case goes to the body’s disciplinary committee instead of another round of guidance. Nothing in the law changed; the supervisor’s approach did.

What mistakes do firms make about OPBAS?

  • Writing to OPBAS with a complaint about their own review. OPBAS does not supervise firms; concerns about the supervisor’s handling go to the body first.
  • Assuming a light touch review last time sets the standard for the next one.
  • Relying on a supervisor’s template without tailoring it to the firm’s actual clients and services.
  • Ignoring the supervisor’s published annual report, which signals where reviews will focus.

Solar Protect runs fee protection schemes for accountancy and bookkeeping practices. See how our accountant schemes work or read fee protection schemes for accountants.

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Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.