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 […]
An accountancy client AML file is tested when someone outside the practice has to understand it. If the reasoning is thin or trapped in memory, good work can still look weak under supervisory review. This article explains how AML supervisors may read an accountancy client file during a review, monitoring visit, or inspection, and what […]
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 […]
In-scope accountancy firms are likely to be subject to an FCA registration or onboarding process once the new AML supervision regime is implemented. There is nothing to apply for yet, because the FCA has not confirmed the exact transition details. For the moment, the current AML rules still apply. Most firms remain under their professional […]
Accountancy firms should expect FCA AML supervision to make compliance more expensive, especially where current supervision costs are low, bundled into wider professional fees, or hard to identify separately. The core reason is the proposed funding model: HM Treasury expects the FCA to recover day-to-day AML costs from the professional services firms it supervises. The […]
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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 |
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