Regulatory Update November 2025

James Price

Hello everyone, and welcome to our November 2025 compliance and regulatory update. Thank you for joining me as we look at the key developments shaping the risk and regulatory landscape this month. I’ll be taking you through several important shifts that firms need to be aware of as we move towards the end of the year, and as always, my aim is to explain not only what has changed but why it matters in practice.

James Price

Let me begin with a significant announcement we’ve had concerning the future of AML supervision across the professional services sector. The government has now confirmed that anti-money laundering supervision for legal services, accountancy services, and trust and company service providers will be brought under a single regulator — the Financial Conduct Authority. What this means is that AML oversight will no longer sit with bodies such as the SRA, CLC, CILEx Regulation, or the Bar Standards Board. Instead, responsibility will be centralised within the FCA, creating what will in effect be a dual regulatory structure for most law firms: professional conduct matters will continue to fall under the SRA, while AML compliance will be overseen by the FCA.

James Price

This decision follows the government’s 2023 consultation on reforming AML supervision, where four models were initially proposed. You may remember those options included an OPBAS+ model, strengthening oversight of existing regulators; consolidating professional body supervisors within each sector; establishing a Single Professional Services Supervisor to cover legal and accountancy AML supervision jointly; and finally, creating a Single AML Supervisor for all sectors nationwide. Following extensive analysis, the government has opted for the Single Professional Services Supervisor model, and they have appointed the FCA to take on that responsibility. New legislation will be required to implement this change, and HM Treasury is due to publish a consultation this month on the specific powers the FCA will need. If this progresses as expected, firms can anticipate increased reporting obligations, new supervisory interactions, and a more structured FCA-driven approach to AML oversight.

James Price

Moving on, I want to turn to an important development relating to practice rights following the case of Julia Mazur & Ora v Charles Russell Speechlys LLP, which we examined in last month’s update. To recap, the Court held that an individual must be personally authorised to conduct litigation, and cannot rely solely on the authorisation of the firm they work for. This ruling has created understandable concern for employed legal staff who do not hold practising certificates — particularly those who, while experienced and capable, are not solicitors or barristers and therefore do not have full litigation rights. In response to these concerns, CILEx Regulation has now submitted a formal application to the Legal Services Board seeking permission to grant full litigation rights to CILEx members who apply for them. This is a significant step, as it could reshape the practising landscape for legal executives and provide firms with greater clarity and flexibility in how they allocate reserved legal activities. We will continue to monitor how the LSB responds to this application and what transitional arrangements may be proposed.

James Price

Before we close, let’s look briefly at the ongoing work surrounding the SRA Accounts Rules. The SRA had indicated that a second consultation on proposed amendments to the Accounts Rules would be published at the end of October 2025. However, no consultation has yet been released. The SRA is still stating that it will appear before the end of the year, so we expect movement shortly. In the meantime, for those seeking a deeper analysis of the themes emerging from the SRA’s wider policy review, Datalaw has recently published a Reporting Accountant Update webinar, which explores the likely direction of future rule changes and what COFAs and reporting accountants should be preparing for.

James Price

As we draw this session to a close, it’s clear that this month brings significant regulatory developments, particularly around AML supervision and the evolving landscape of practice rights. These shifts underline the importance of staying agile, informed, and proactive in your compliance planning. We will continue to keep you updated as consultations open, decisions are finalised, and new rules begin to take shape. Thank you for joining me for this November update.