The JMLSG’s Future in a Centralised UK AML Regime
The United Kingdom’s decision to consolidate anti-money-laundering and counter-terrorist-financing supervision under the Financial Conduct Authority (FCA) marks one of the most significant structural shifts in anti-money laundering (AML) oversight since the Money Laundering Regulations (MLRS) were first introduced. If, as planned, the new Single Professional Services Supervisor (SPSS) model is implemented—subject to legislation and a managed transition—the FCA will assume responsibility for supervising the legal, accountancy, and trust and company service provider sectors. It is an historic step towards greater public-sector consistency and a more risk-based approach to regulation in the UK.
What Will Regulatory Consolidation Mean for the JMLSG?
Against this backdrop, an important question is quietly emerging across the compliance and regulatory community: what becomes of the Joint Money Laundering Steering Group? For more than two decades, the JMLSG has provided the financial sector with authoritative, Treasury-approved guidance on applying the MLRS. Its principles on risk assessment, customer due diligence and ongoing monitoring have long acted as the practical foundation for firms navigating the complex interface between legislation, FCA expectations and day-to-day compliance.
The JMLSG’s value has always rested on its ability to bridge policy and practice. It translates regulation into usable procedures and maintains a consensus between banks, building societies, insurers, and investment firms. Yet, as the FCA’s remit expands beyond financial services to encompass professional firms, it will have both the mandate and the capability to issue its own detailed supervisory guidance. That shift could blur the traditional boundaries between statutory regulator and industry standard-setter.
In one sense, the FCA’s growing authority strengthens the case for a refreshed, perhaps even redefined, JMLSG. The FCA’s rules and Financial Crime Guide provide the regulatory baseline, but firms continue to rely on the JMLSG to interpret proportionality and evidence good practice in risk-based decision-making. The FCA may set the expectation, but it is the JMLSG that explains what “good” looks like in operational terms.
As the supervisory perimeter widens to include professional services, there will be an even greater need for practical alignment across sectors that previously sat under entirely different supervisory bodies. A revised JMLSG could become the focal point for cross-sector consistency—helping to harmonize expectations between the FCA’s financial and professional services populations.
Alternatively, some may argue that consolidation makes the JMLSG less essential. If a single regulator is responsible for both policy enforcement and supervisory interpretation, why maintain an industry-led body at all? The answer lies in the balance between rule-setting and operational insight. Regulators can mandate standards, but effective implementation depends on shared understanding and technical nuance that only practitioners can provide. The risk of dissolving or sidelining the JMLSG would be the loss of that collaborative mechanism which has long underpinned the UK’s proportionate, outcomes-based approach. Once the professional body supervisors hand over their AML responsibilities, the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) will also wind down—a reminder of how institutional consolidation can simplify oversight but narrow the channels for dialogue.
What Does the Future Hold for AML in the UK?
The likely future is neither abolition nor preservation by inertia, but evolution. The JMLSG could reposition itself as a multi-sector AML standards forum working in structured partnership with the FCA. Its guidance could focus more on emerging risks, technology integration and sectoral best practice rather than codifying existing rules. It might even extend its remit to professional services under the new FCA umbrella, ensuring a common interpretive thread that links banks, lawyers, and accountants under one supervisory language.
In an increasingly international context, the UK’s ability to demonstrate credible, risk-sensitive supervision will depend on retaining a channel for industry expertise to shape implementation. The FCA’s expanded powers will deliver consistency and enforcement capability, but enduring effectiveness will still require dialogue, consensus and agility. The JMLSG, if it adapts, remains uniquely placed to provide that connective tissue.
The UK’s AML reform is about simplification and coherence, but not centralization at the expense of collaboration. The next few years will determine whether the JMLSG becomes a legacy institution or a renewed partner in a more unified regulatory architecture. Its future relevance will not rest on its historic role as interpreter of the rules, but on its capacity to help the FCA and industry navigate what comes after the rules are rewritten.