While Suspicious Activity Reports (SARs) are a rare event for small accountancy firms, the difficulty lies in knowing when an unusual client matter has moved beyond a routine query. This judgment is fundamental because the wrong response can create real anti-money laundering (AML) compliance problems for the firm. Staff must know when to escalate a […]
AML responsibility cannot only sit with the person updating files or handling onboarding checks. The people who control the practice need to understand how AML risk affects the work being accepted, approve an approach that fits the firm, and keep enough evidence to show that oversight is real. This article explains what senior management AML […]
A firm-wide risk assessment and a client risk assessment are both part of anti-money laundering compliance, but they serve different purposes. The firm-wide risk assessment takes a practice-wide view, and it helps the firm understand where its money laundering, terrorist financing, and proliferation financing risks are likely to arise. The client risk assessment brings that […]
A firm-wide risk assessment (FWRA) should explain how an accountancy practice could be exposed to money laundering, terrorist financing, and proliferation financing. Under Regulation 18 of the Money Laundering Regulations, firms must keep an up-to-date assessment of their financial crime exposure and ensure it informs their AML procedures. If the assessment is generic or disconnected […]
The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 change several areas that accountancy firms may need to reflect in their anti-money laundering (AML) controls. The main effect is on how firms word and operate their core AML controls, including customer due diligence (CDD) and enhanced due diligence (EDD), geographic-risk checks, client-account controls, and trust […]
When an existing client asks for additional work, the practice should check whether its AML understanding still fits the proposed service. This depends on the service scope, what is already known about the client, and whether the extra instruction creates information gaps. While the request does not automatically mean full re-onboarding, the decision should still […]
A scheduled AML review does not always lead to new document requests, a revised risk rating, or further client questions. In many cases, the review simply confirms that the existing AML position remains adequate. That said, the record should still show why the firm was satisfied that no AML update was needed, so the decision […]
A CDD refresh does not automatically require an accountancy firm to collect new ID from an established client. Existing evidence may remain usable if the original check was properly completed, and the client details remain consistent. The firm should also be satisfied that relying on the original ID still fits the current risk assessment. Updated […]
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 […]
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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 |
| ✓ | 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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