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 […]
Accountancy firms must assess how remote onboarding, digital communication, and third-party delivery affect their ability to understand each client relationship. This becomes especially relevant when the firm is not dealing directly with the client or is relying too heavily on information from one channel. By extension, this makes it harder to confirm who is involved […]
A firm-wide risk assessment (FWRA) must show where the practice’s geographic exposure comes from across its client base. This includes the countries connected to the client’s business activities, ownership, and financial arrangements, as well as the locations that the practice operates. In most cases, the geographic section of the FWRA can be organised around information […]
Small accountancy firms must decide whether their AML arrangements require independent testing under Regulation 21 and who can perform that work with sufficient separation. Any review carried out for that purpose should establish whether the practice’s controls operate effectively in day-to-day work and whether identified weaknesses are sufficiently addressed. Whether independent testing is needed depends […]
Every accountancy practice is responsible for assessing how its services could be used to conceal criminal funds, support misleading financial records, or give credibility to questionable activity. In practice, the firm-wide risk assessment (FWRA) should begin with the services the practice actually provides. Each service line is important because it affects what the firm is […]
Accountancy firms are responsible for checking that employees whose work affects AML compliance have the competence and integrity needed for their role. This assessment applies when the employee is appointed and continues while they carry out relevant duties. The way responsibility is organised will depend on the practice. A larger firm, for example, might divide […]
Accountancy firms need to keep their firm-wide risk assessment (FWRA) and AML policies aligned with the way the business actually operates. This means setting a sensible review cycle and knowing when changes in the practice, such as client base or services, require a review before the planned date. The size and structure of the practice […]
Accountancy practices must evaluate how HMRC’s sector guidance affects their firm-wide risk assessment (FWRA). The FWRA should show which risks are relevant to the practice and how the firm reached its conclusion. How HMRC’s guidance is applied will depend on the size and structure of the practice. A sole practitioner, for example, might approach the […]
AML duties do not disappear because an accountancy practice is run by one person. While a sole practitioner does not need the same compliance structure as a larger firm, supervisors still expect to see how AML risks are being assessed, managed, and reviewed in practice. The core issue is how these responsibilities sit with the […]
In a small accountancy practice, the MLRO role is significantly more important than an administrative appointment. It is the point at which internal concerns about possible money laundering are assessed and, where necessary, turned into an external report. The role needs someone with direct access to the client file and engagement context, as well as […]
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| ✓ | Practical updates on CDD refresh, ongoing monitoring, and AML review records |
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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.
What’s included:
| ✓ | What the FCA transition means for small accountancy firms in real terms |
| ✓ | The AML records and evidence supervisors will look for |
| ✓ | Common weak spots in ongoing AML monitoring, rationale, and file updates |
| ✓ | Practical steps to get cleaner, more defensible AML files before 2028/29 |
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