If a trigger event occurs, it means a development was identified during the client relationship that may affect the reliability of existing CDD. A client AML record should not be left unchanged simply because the next planned review date has not arrived. Regulation 28 of the Money Laundering Regulations provides the main legal anchor because […]
CDD refresh for existing accountancy clients: What should be checked?
A CDD refresh helps an accountancy firm decide whether the client information held on file remains accurate and sufficient for AML purposes. The Money Laundering Regulations require firms to keep CDD information up to date during a business relationship, which means reviewing the areas most likely to affect the firm’s AML understanding. Key review areas […]
How often should accountants update CDD for existing clients?
UK accountants do not have one fixed legal deadline for refreshing customer due diligence (CDD) on every existing client. Instead, the timing should be risk-based. A firm’s AML procedures should set out when periodic CDD reviews take place, how those timings vary by client risk, and what events bring a review forward. The important point […]
What ongoing monitoring means for accountants under UK AML rules
Ongoing monitoring is the part of AML that starts after a client has been onboarded. It is also where the compliance process becomes less structured. This is because AML is often treated as a front-loaded exercise: collect ID, understand the client, assess the risk, and open the file. But Regulation 28 of the Money Laundering […]





