What is an AML supervisor?
An AML supervisor is the body that checks your firm complies with the Money Laundering Regulations 2017 (MLRs). Every regulated business must have one. Under regulation 7, it is HMRC, the FCA, the Gambling Commission or one of 22 professional bodies, depending on your sector and membership. Supervisors register, inspect and can fine firms.
Your supervisor is also the first place to look for sector guidance and risk information, which your firm-wide risk assessment must take into account (reg 18(2)).
Who supervises whom
| Your business | Usual AML supervisor | Notes |
|---|---|---|
| Estate agency business | HMRC | Register with HMRC for money laundering supervision |
| Letting agency business (rent of £10,000 a month or more) | HMRC | Threshold in sterling since 30 June 2026 |
| Accountant, bookkeeper or tax adviser | Your professional body (for example ICAEW, ACCA, AAT, ICB), or HMRC if you have none | Membership alone may not be enough: check your body supervises your firm |
| Solicitor or conveyancer | The Law Society (through the SRA), the CLC, or the equivalent body in Scotland or Northern Ireland | |
| Financial adviser (FCA-authorised) | The FCA | |
| Trust or company service provider | The FCA, a professional body or HMRC | Cannot trade until registered, if HMRC-supervised |
| Money service business, high value dealer, art market participant | HMRC, or the FCA for some MSBs | |
| Casino | The Gambling Commission |
The 22 professional bodies are listed in Schedule 1 of the MLRs. Not sure which applies to you? Use our free AML supervisor checker.
Sources: MLR regulation 7 and Schedule 1; GOV.UK: who needs to register with HMRC.
What your supervisor expects from a small firm
- Registration with your supervisor, and payment of its fees. HMRC’s fees since 1 December 2025 are £300 per application and £400 per premises each year. Work yours out with the HMRC AML fees calculator.
- Notification of your nominated officer within 14 days of appointment (reg 21(4)).
- Your written risk assessment, policies and client files on request, including during an inspection.
- Changes reported when your business, premises or key people change.
HMRC publishes the businesses it has fined. See the HMRC AML fines tracker and our guide to preparing for an HMRC AML inspection.
Supervision is changing
- Professional services move to the FCA. In October 2025 the government decided the FCA will take over AML supervision of legal, accountancy and trust or company service providers. The FCA expects a phased transfer from late 2028, completing around 2030. No legal start date has been set, and your current supervisor stays responsible until then. Read FCA as AML supervisor for professional services.
- Fewer supervisors. The Home Office AML strategy published on 15 September 2026 plans to cut the number of supervisors from 25 to 3.
- Oversight of professional bodies sits with OPBAS, which is hosted by the FCA.
Track these dates in our AML deadlines calendar.
Frequently asked questions
Who is the AML supervisor for estate agents?
HMRC. Estate agency businesses must register with HMRC for money laundering supervision. Letting agency businesses in scope are also supervised by HMRC.
My accountancy body is ICAEW. Do I also register with HMRC?
Not if ICAEW supervises your firm for AML. If you are a member but your firm is not covered by your body’s AML supervision, HMRC is your supervisor. Check with your body.
Can I trade while my HMRC registration is pending?
HMRC says most businesses can trade while their application is processed, but money service businesses and trust or company service providers must wait for confirmation. Trading without applying at all is an offence.
Will the FCA supervise estate agents?
The October 2025 decision covers legal, accountancy and trust or company service providers. Estate and letting agents are not part of the FCA transfer announced so far.
How AML Buddy helps
Supervisors expect customer due diligence evidence on every client file. AML Buddy gives you a timestamped PDF report for each check, covering identity, address, sanctions, PEP and adverse media. See pricing.
Go deeper: read which AML supervisor do I need?.