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 and sufficient for AML purposes. The Money Laundering Regulations require firms to keep CDD information up to date during a business relationship, which means reviewing the areas most likely to affect the firm’s AML understanding. Key review areas […]
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 that starts after a client has been onboarded. It is also where the compliance process becomes less structured. This is because 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 […]
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 oversight to make compliance more expensive, especially when current supervision costs are low, bundled into wider professional fees, or hard to identify separately. The funding direction is now confirmed in policy, with the FCA expected to recover day-to-day AML supervision costs from the professional services firms it supervises. The […]
The Financial Conduct Authority (FCA) will take over anti-money laundering (AML) supervision of accountants, but there is no confirmed start date yet. Despite the UK government confirming the future AML framework in October 2025, the change still needs legislation before it can take effect. The safest working assumption for accountancy firms is that current supervision […]
The Financial Conduct Authority (FCA) will become the single public supervisor for anti-money laundering (AML) and counter-terrorist financing across UK accountancy firms, once the required legislation, funding arrangements, and transition plan are in place. Our FCA transition report for small accountancy firms covers what’s changing, who’s affected, key timelines, and how to prepare. Latest development: […]
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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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