AML record keeping ensures accountancy firms can evidence how they discharged their obligations under the Money Laundering Regulations. In addition to basic identity checks, records should extend to client risk assessments, employee instruction, internal disclosures, and how regulated information is eventually disposed of. Just as importantly, sensitive material such as suspicious activity reports (SARs) must […]
UK accountancy firms can currently be supervised for AML by HMRC, a recognised professional body such as ICAEW or ACCA, or, in more limited circumstances, the FCA. Which supervisor applies depends on the firm’s regulatory circumstances, not simply an individual accountant’s professional membership. Although the FCA is due to take over AML supervision for the […]
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 […]
UK accountancy firms that carry out regulated work must organise their AML responsibilities around the services they provide, the clients they accept, and the risks they encounter in practice. The principal obligations sit under the Money Laundering Regulations 2017 (MLR 2017) and the Proceeds of Crime Act 2002 (POCA), supported by HM Treasury-approved guidance for […]
AML policies, controls, and procedures (PCPs) explain how an accountancy firm puts its money laundering risk assessment into daily practice. They set out how client due diligence is applied and how AML decisions are made and recorded. These arrangements are important to regulators because the risk assessment identifies the firm’s exposure, while the PCPs explain […]
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 an accountancy practice submits an external suspicious activity report (SAR), it must turn information from the client engagement into financial intelligence that law enforcement can understand and use. The narrative needs to identify the relevant people, activity, and suspected criminal property, then clearly show how the available evidence led to suspicion. The reporting duty […]
When an existing client review uncovers an unexplained transaction, inconsistency, or gap in the supporting evidence, accountancy firms must decide whether standard enquiries can resolve the matter or whether it should be escalated as a suspicion. The outcome can affect work already underway, particularly when a filing or piece of advice is linked to the […]
Accountants must know how to respond when information gathered before accepting a client points to possible money laundering or terrorist financing. While routine onboarding questions can resolve an inconsistency, if the available facts support suspicion, the practice must stop the engagement from progressing and use its formal reporting process. The person who identifies the AML […]
When an accountant identifies information that may require a suspicious activity report (SAR), the practice must preserve a clear record of the concern and the money laundering reporting officer’s (MLRO) response. That information must remain separate from routine client papers so that staff, clients, and service providers do not discover the existence of the case […]
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| ✓ | Exclusive discounted pricing before the public launch |
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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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