Helping small regulated firms evidence ongoing monitoring compliance
Evidentia was created for small UK accountancy firms that need a clearer way to record periodic reviews, changes in client circumstances, and the AML judgement behind each decision.
Why we built Evidentia
Evidentia was founded because of the ever-increasing gap between AML expectations and the day-to-day reality of small UK accountancy firms.
Solo practitioners, owner-led firms, and micro practices are expected to show that AML checks have been reviewed properly over time, even when the responsibility sits with one busy owner or senior person who is also trying to run the practice and serve clients. The key challenge is that keeping existing client AML records current has become a stressful and non-billable burden.
Research suggests that AML compliance becomes more difficult to evidence after onboarding is complete. Under the Money Laundering Regulations, a periodic review, a change in ownership or services, or an unusual development can all require the firm to revisit the client’s AML position and create a record that still makes sense months or years later.
We found that many small firms keep AML records across templates, spreadsheets, email threads, and client files, while follow-ups often depend on reminders or memory. Each note may make sense at the time, but the record trail can become fragmented, making it harder to show how the AML risk profile has been reviewed if the file is inspected.
Evidentia was created to address this issue specifically. Instead of treating CDD refreshes and scheduled reviews as separate admin jobs, Evidentia brings each update into a guided flow with prompts, evidence references, follow-up tracking, and a running chronology. Firms still apply their own professional judgement, but the supporting AML trail is no longer left across disconnected places.
Firms therefore have a stronger basis for responding to an AML supervisor without having to reconstruct the file under pressure.
Post-onboarding AML compliance
The Money Laundering Regulations demand ongoing monitoring, up-to-date records, and clear evidence of review.
Designed for small-firm reality
Structured around AML obligations, but built for firms without a dedicated compliance team or heavy admin capacity.
Records that explain the decision
Capture what was reviewed, what changed, the conclusion, referenced evidence, and why the decision was reasonable.
Easy to start, easy to keep using
Evidentia provides one-to-one setup support to help firms configure their workspace and use the product confidently.
FCA supervision will change AML standards. Small firms must prepare.
As the FCA transition develops, small accountancy firms will need to show how ongoing monitoring and CDD refreshes are handled in practice. Evidentia helps firms move from fragmented AML notes to inspection-ready records.
The weaknesses are already showing up in AML reviews.
Public supervisory material repeatedly identifies gaps in CDD, ongoing monitoring, review rationale, evidence quality, and whether controls operate in practice.
Reviewed firms found non-compliant
AAT reviewed 327 supervised firms and found almost one in four non-compliant. Its breach findings included weaknesses in initial CDD, ongoing due diligence, policy reviews, and PSC checks.
Source: AAT AML annual report →Non-compliant in PBS firm sampling
HM Treasury reported that PBS sampling of medium and low-risk supervised firms still found non-compliance, including inadequate CDD, weak client risk records, and firm-wide risk assessment issues.
Source: HM Treasury supervision report →AML supervisors are being replaced
The current AML model spans 22 professional body supervisors plus relevant HMRC activity. The reform moves professional services oversight toward one FCA-led public authority.
Source: HM Treasury reform response →What supervisors keep finding, and how Evidentia responds
Evidentia focuses on the points that often create pressure for small firms. It helps users start the right review, record the rationale, keep evidence and follow-ups connected, and produce a clearer answer when the AML file is requested.
Changed client facts can require a CDD refresh
HMRC’s supervision manual says certain changes can “trigger a review of CDD”. That supports the point that CDD is not just an onboarding exercise.
Source: HMRC supervision manual →Change events are routed into structured review workflows
Periodic reviews, ownership changes, new directors, service-scope changes, unusual developments, and other AML-relevant events can be handled through a guided review/update flow.
Supervisors care whether controls actually operate
HMRC says supervisors should test whether what firms describe in policies, controls, and procedures is actually “happening in practice”.
Source: HMRC supervision manual →Completed records show the AML work was actually done
Evidentia turns reviews and updates into completed records that show why the AML review started, what was checked, what decision was made, and what evidence or follow-up supported it.
Rationale is often too thin or missing
ACCA’s common findings refer to records that “lacked sufficient detail” and cases with “no supporting rationale”. That is exactly where many small firms struggle.
Source: ACCA AML supervision report →Rationale support removes the blank page
Sentence starters, full examples, and reusable rationale patterns help users explain what they considered, why the conclusion was reasonable, and what action followed.
Weak evidence trails keep appearing in reviews
ACCA highlights the need to “retain clear evidence”, while AAT uses “insufficient evidence” when firms cannot show that AML controls are effective.
Source: ACCA AML supervision report →Evidence references stay connected to the review
Users can reference the material relied on, such as existing CDD, Companies House checks, AML tool results, client explanations, internal notes, or other supporting material.
Unresolved AML issues can lead to further action
AAT reported 7 follow-up reviews, with 4 firms failing and being terminated. That shows unresolved AML remediation can quickly become a serious supervisory issue.
Source: AAT AML annual report →Open AML matters stay visible until resolved
Records awaiting evidence, clarification, or further action remain open until the follow-up is completed and recorded. Completed records preserve the outcome rather than overwriting unresolved work.
A more formal AML supervisor means small firms need clearer evidence.
The move toward FCA supervision is expected to bring more consistent oversight, stronger information-gathering powers, a more formal registration model, and greater pressure to show that AML controls work in practice.
A defensible AML record depends on more than stored documents. Accountancy firms need to show how the client’s position was kept under review and why the AML judgement made at the time was reasonable.
Evidentia ensures compliance work has a structured flow, so the file does not depend on scattered notes when questions are asked.
What is changing
The FCA will become the single public supervisor for AML regulation in the accountancy sector.
Why it matters
Firms will need clearer evidence of ongoing monitoring, CDD refreshes, and trigger-based reviews.
What to prepare now
Records must show what changed, what was reviewed, and why the firm reached its AML conclusion.
FCA AML supervision for accountants
Our briefing for small accountancy firms covers what is changing, who is affected, key timelines, and what to do now.
Read the FCA report →