8.2.1. United Kingdom: The supervisor of DNFBP supervisors (OPBAS) experience

263. Financial Institutions have historically been more tightly regulated for AML/CFT than the DNFBP sectors. This has driven significant investment in FI AML systems and controls; for example, technology to monitor transactions. Similar oversight by the DNFBP supervisors of their relevant firms has been lower in places, although, through OPBAS's work with SRBs, that has started to change.

264. SRB designated as DNFBP supervisors under the money laundering regulations are overseen by OPBAS and cover a wide range of sub-sectors including tax advisory, audit, insolvency, conveyancing and trust company formation, and cover roles including accountants, bookkeepers, solicitors, barristers and notaries across England and Wales, Scotland and Northern Ireland. The vulnerabilities can be specific to each activity the supervised entity undertakes. Risks in these sectors are continually developing, for example sham litigation, or planting Organised Crime Gang members into a firm due to weak staff screening processes.

265. At the start of its regulatory work in 2018, OPBAS identified a number of concerns. For example, it needed to obtain buy-in around the value of AML systems and controls; some supervisors, and some firms within their supervised population, didn't view AML as a core function.

266. A lack of focus on AML supervision by some DNFBP supervisors meant their systems and controls lacked sophistication, with some viewing AML as a tick box exercise.