When customer due diligence (CDD) is incomplete, an accountancy firm must decide whether it can start work for a new client or continue acting for an existing one.  The decision affects both client handling and the AML record, especially if work is paused or the incomplete CDD requires internal escalation. Until the necessary checks are […]

Accountants sometimes need to understand where a client’s money has come from before they can be comfortable with the AML risk.  This might involve checking the source of funds behind a particular payment, loan, or receipt. In some higher-risk cases, the firm may also need to understand a connected person’s wider source of wealth. For […]

When a prospective client has a layered company, partnership, or trust structure, accountancy firms must establish which individuals ultimately own the client and who can direct its affairs.  AML compliance work also needs to show why the arrangement exists and whether it makes commercial sense in relation to the client’s activities. Therefore, for complex ownership […]

When a private company applies to become a client, the accountancy firm must establish which individuals ultimately own or control it.  Their identities must be checked, and the AML file must show why the practice was satisfied with the ownership position before accepting the engagement. The depth of the work should reflect the complexity of […]

When an existing client asks for additional work, the practice should check whether its AML understanding still fits the proposed service.  This depends on the service scope, what is already known about the client, and whether the extra instruction creates information gaps.  While the request does not automatically mean full re-onboarding, the decision should still […]

A scheduled AML review does not always lead to new document requests, a revised risk rating, or further client questions. In many cases, the review simply confirms that the existing AML position remains adequate. That said, the record should still show why the firm was satisfied that no AML update was needed, so the decision […]

A CDD refresh does not automatically require an accountancy firm to collect new ID from an established client. Existing evidence may remain usable if the original check was properly completed, and the client details remain consistent. The firm should also be satisfied that relying on the original ID still fits the current risk assessment. Updated […]

Beneficial ownership changes can affect an accountancy firm’s AML position because the earlier CDD may no longer describe the client as it is now. For a company or other legal entity, AML is concerned with the person with ultimate ownership, control, or benefit from the business. This is sometimes referred to as the ultimate beneficial owner, […]

AML reviews for existing clients need to leave a clear record of the judgement made at the time. If the client file is reviewed later, the entry should make the judgement understandable. It needs to explain why the review took place, identify the material considered, and give the basis for the conclusion. Under the Money […]

Accountancy firms deal with changes in client circumstances throughout a relationship. Some are routine file updates, while others can alter the AML judgement already made, including whether existing CDD remains reliable. Alongside ongoing monitoring, UK AML rules require CDD information to be kept current on a risk-sensitive basis. They do not give a fixed statutory […]