FCA Delivers Historic Censure on ICB AML Failings
The UK Financial Conduct Authority (FCA) has issued its first-ever public censure against a professional body supervisor for anti-money laundering (AML) supervision shortcomings. On December 1, 2025, the FCA targeted the Institute of Certified Bookkeepers (ICB), a not-for-profit organisation overseeing more than 3,000 bookkeepers under the Money Laundering Regulations 2017 (MLRs 2017). This landmark enforcement action underscores the regulator’s commitment to upholding rigorous standards amid rising financial crime threats in professional services.
ICB’s breaches spanned from January 2022 to July 2023, during which it failed to implement an adequate risk-based supervisory approach and neglected effective member monitoring. The most critical lapse involved suspending all onsite and virtual inspections for nine months, severely hampering compliance scrutiny and elevating sector-wide money laundering vulnerabilities. Therese Chambers, joint executive director of enforcement and market oversight at the FCA, emphasised that such AML rules prevent criminal exploitation of the financial system while safeguarding consumers, businesses, and market integrity.
Detailed Breakdown of ICB’s AML Supervision Breaches
ICB, based in High Wycombe and one of 25 Professional Body Supervisors (PBSs) under the FCA’s Office for Professional Body Anti-Money Laundering Supervision (OPBAS), bears statutory responsibility for ensuring its members adhere to MLRs 2017 provisions. The FCA identified multiple regulatory violations, primarily stemming from inadequate oversight mechanisms that compromised the body’s ability to detect and mitigate financial crime risks among bookkeepers. No financial penalty was imposed, as the OPBAS Regulations 2017 limit FCA powers to public censure in these cases, though the Final Notice publication serves as a significant reputational deterrent.
The nine-month inspection halt proved particularly damaging, as it eliminated a core tool for verifying member compliance with AML obligations. This decision exacerbated broader deficiencies, including insufficient risk assessments and monitoring protocols tailored to bookkeeping activities prone to illicit finance abuse. OPBAS, established to bolster the UK’s AML framework, supervises PBSs like ICB to maintain consistent enforcement across legal and accountancy sectors.
Broader Context: UK’s AML Supervisory Reforms
This censure arrives against a backdrop of sweeping government reforms to centralise AML/CTF supervision under the FCA as the Single Professional Services Supervisor. Announced in October 2025, the shift aims to address fragmentation among PBSs overseeing approximately 60,000 firms, including accountancy, legal, and trust services providers. Primary legislation will empower the FCA, with stakeholder consultations and implementation timelines pending parliamentary availability.
Professional bodies have invested heavily in supervision enhancements, yet critics like the Institute of Chartered Accountants in England and Wales (ICAEW) warn that FCA consolidation could raise compliance costs and erode sector-specific expertise. The Institute of Chartered Accountants of Scotland (ICAS) expressed surprise at the move, advocating evolution of the existing PBS model over wholesale transfer. In the interim, OPBAS will intensify collaboration with PBSs to enforce compliance, signalling no relaxation in standards pre-reform.
Implications for Bookkeepers and Professional Supervisors
Bookkeepers under ICB now face heightened scrutiny, as the censure highlights elevated financial crime risks from lapsed oversight. Firms must prioritise robust AML controls, including business-wide risk assessments, customer due diligence, and ongoing transaction monitoring, to avoid similar regulatory pitfalls. The FCA’s action sets a precedent, demonstrating willingness to pursue enforcement where PBS oversight falls short of expectations.
Legal and accountancy sectors anticipate stricter FCA enforcement post-reform, mirroring hefty penalties imposed on financial institutions for AML gaps. While SRA-led supervision for solicitors ends, the transition promises uniform standards but potential cost hikes for smaller practices. Compliance professionals urge immediate gap analyses against identified weaknesses, such as vague policies and group-based risk ratings, to preempt enforcement.
FCA’s Ongoing AML Enforcement Stance
The FCA has ramped up AML interventions, issuing “Dear CEO” letters flagging common failings like deficient risk assessments and monitoring in Annex 1 firms. Firms must conduct comprehensive reviews within six months, documenting remedies under senior management oversight. Therese Chambers reiterated that strong supervision operationalises AML safeguards, protecting market trust.
This ICB case reinforces the regulator’s proactive posture amid illicit finance challenges, including cryptocurrency laundering and sanctions evasion. As reforms unfold, PBSs must elevate practices to align with FCA benchmarks, ensuring the bookkeeping sector mitigates money laundering effectively. Stakeholders anticipate further actions to deter complacency across professional services.