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, […]
Accountancy firms deal with changes in client circumstances throughout a relationship. Some are routine file updates, while others may 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 […]
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 […]
A CDD refresh helps an accountancy firm decide whether the client information held on file remains accurate, reliable, and sufficient for AML purposes. The Money Laundering Regulations require firms to keep CDD information up to date during a business relationship. This means reviewing the areas most likely to affect the firm’s AML understanding, including ownership, […]
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 […]
Ongoing monitoring is the part of AML compliance that starts after a client has been onboarded. This is where many firms run into trouble. 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 Regulations makes clear that […]
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FCA supervision will bring tougher scrutiny, clearer evidence expectations, and less room for messy AML files. This report explains what is changing and what small firms should tighten now.
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| ✓ | What the FCA transition means for small accountancy firms in real terms |
| ✓ | The AML records and evidence supervisors will look for |
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