The announcement that the FCA is to take over AML supervision has made us prick up our ears. If and when it happens, it might require us to rethink our approach to AML Compliance generally.
This, along with a fresh approach to Source of Wealth and Source of Funds enquiries, a fresh list of high risk countries published in February 2026, a refreshed focus on operational compliance and some forthcoming Amendment Regulations due in ‘early 2026’ all add up to the latest round of modifications to an already overburdened system.
The unremitting force of the SRA may have taken a slightly less threatening tone since the advent of Sarah Rapson as the new CEO, but that does still not give us any excuse to back-pedal on our compliance requirements.
Oh, and war in the Middle East and the sanctions regime….it seems to be one battle after another.
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Trevor Hellawell
CEO • ExL Practice Development
Trevor Hellawell is a solicitor and legal training and management consultant working with major law firms, local law societies, many legal training providers and other clients. Until going freelance in 1999 he was a full time lecturer with the University of Law, ending his career as a Principal Lecturer at the York Branch. Until recently returning to the freelance arena, he was Head of Law Programmes at BPP.
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