On 29 September 2023, The Wolfsberg Group submitted its response to HM Treasury's public consultation on the Reform of the UK Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Supervisory Regime.

Of the four models for reform outlined by HM Treasury, we believe that a public body Single Professional Services Supervisor (SPSS), i.e. ‘Model 3’, is best suited to address inconsistencies and systemic weaknesses in supervision, as it would: a. Enhance information sharing, public-private partnerships, and a focus on national threat priorities; b. Promote risk-based and outcome-based supervision; c. Ensure dissuasive sanctions; d. Support cross-cutting government policies.

The Group also recommends that consideration is given to transitioning the supervision of higher-risk sectors, as identified by the UK’s National Risk Assessment, from HM Revenue & Customs to the Financial Conduct Authority.

We are grateful for the opportunity to comment on the proposal and welcome dialogue with HM Treasury on enhancing the effectiveness of the UK’s supervisory and sanctions regimes.