Accountants and Bookkeepers

UK accountants and bookkeepers are subject to the Money Laundering Regulations and must be supervised for AML compliance by an approved supervisory body.

Currently, supervision is carried out either by a recognised professional body or by HM Revenue & Customs (HMRC). Professional body supervisors include organisations such as the Association of Chartered Certified Accountants (ACCA), the Institute of Chartered Accountants in England and Wales (ICAEW), the Institute of Chartered Accountants of Scotland (ICAS), the Chartered Institute of Management Accountants (CIMA) and the Association of Accounting Technicians (AAT).

All supervisors expect firms to operate effective AML frameworks, including appropriate governance arrangements, a documented firm-wide risk assessment, robust CDD and enhanced due diligence procedures, sanctions and PEP screening, staff training, SAR reporting processes and proper record keeping. 

Supervisors conduct regular reviews and inspections throughout the year and expect firms to evidence that controls operate effectively in practice, not just on paper.

This framework is set to change. The UK Government has confirmed reforms that will transition AML supervision for professional services firms, including accountants and bookkeepers, to the Financial Conduct Authority (FCA), with firms required to register directly under a more structured and centralised regime.

Under FCA supervision, accountants and bookkeepers will be expected to demonstrate that their AML arrangements are robust, proportionate and operating effectively in practice, rather than existing solely as documented policies.

In particular, the FCA will expect firms to be able to evidence:

• A firm-wide risk assessment that accurately reflects the services provided, client base and delivery model
• AML policies, controls and procedures that are tailored to the firm and embedded in day-to-day operations
• Effective customer due diligence and enhanced due diligence, applied consistently and supported by clear records
• Strong governance and oversight, including clear accountability at senior management and AML lead level
• Appropriate ongoing monitoring of client relationships
• Training that is role-appropriate, regularly refreshed and properly documented
• Clear audit trails and evidence demonstrating how AML decisions are made, reviewed and escalated

The FCA places particular emphasis on consistency, governance and evidence. Firms that are unable to clearly demonstrate how AML controls operate in practice — even where policies exist — are likely to face supervisory challenge.

Accountants and bookkeepers should therefore ensure their AML frameworks are capable of meeting the higher, more consistent standards expected under FCA supervision.

The AML Practice offers comprehensive support to accountancy and bookkeeping firms, meeting all their AML compliance needs, including: 

AML Gap Analysis

We conduct a structured review of your existing AML framework against current UK supervisory expectations for accountants and bookkeepers.

This includes your:

• Firm-wide risk assessment
• AML policies and procedures
• Governance and oversight arrangements
• Training records
• Client due diligence practices
   

You receive a clear written gap analysis identifying risks, weaknesses and practical remediation steps.

AML Audits & Independent Reviews

We carry out AML audits and independent reviews designed specifically for accountancy practices, assessing both design and operational effectiveness.

Our audits focus on:

• Whether controls are proportionate to your risk profile
• Whether they are consistently applied across the firm
• Whether decisions and reviews are properly documented
   

Audit outputs are clear, pragmatic and suitable for internal governance or supervisory engagement.

FCA Supervision Preparation & Application Support

As AML supervision transitions to the FCA, firms will be expected to demonstrate stronger governance, clearer accountability and improved evidence.

We support accountants and bookkeepers by:

• Aligning AML frameworks to FCA supervisory expectations
• Reviewing governance and oversight arrangements
• Supporting FCA onboarding, engagement and supervisory readiness
• Ensuring documentation and controls are regulator-ready
   

Our aim is to ensure your firm transitions smoothly into the new supervisory regime.

Annual AML Compliance Attestation

We assist firms with annual AML compliance attestations, helping to evidence that:

• AML controls remain appropriate and effective
• Risk assessments have been reviewed and updated
• Policies and procedures remain aligned to current guidance
• Training obligations have been met
   

This creates a clear annual compliance record for governance, audit and supervisory purposes.

AML Training for Accountants & Bookkeepers

We provide role-specific AML training programmes designed for accountancy practices and bookkeeping firms. Training is delivered through a structured e-learning format, supported by assessment and completion records, and is tailored to the risks faced by the accountancy sector.

Our accountant-focused AML training covers:

• Sector-specific money laundering risks, red flags and typologies relevant to accountancy services
• Client due diligence and ongoing monitoring expectations in practice 
• Source of funds and source of wealth considerations for different client types 
• Escalation processes, SAR decision-making and MLRO responsibilities 
• Practical case studies to support real-world application
   

Training is designed to support firms in meeting their AML training obligations and to provide clear evidence of staff competence and understanding.
 

Training can be delivered to partners, staff and management, with full attendance and completion records.

Ongoing Support & Retainers

For firms seeking a single, joined-up AML solution, we offer ongoing AML support on a retainer basis.

Our retainers combine the core AML services set out above into one engagement, at a discounted overall price, including:

• AML gap analysis 
• AML audit or independent review 
• FCA supervision preparation and application support
• Annual AML compliance attestation 
• Role-specific AML training programmes
   

In addition, retainers include ad-hoc AML support to assist firms with day-to-day compliance queries, such as:

• SAR considerations and escalation decisions 
• Higher-risk clients and enhanced due diligence scenarios 
• Unusual or complex client risk situations 
• Interpretation of updated guidance or supervisory feedback
   

This model provides continued assurance, practical support and cost efficiency, while allowing firms to retain full responsibility for AML decision-making and oversight.

Our Approach

We work with law firms in a way that is:

• Practical and proportionate
• Focused on evidence, not just documentation
• Aligned to both current legal sector guidance and future FCA expectations
• Designed to stand up to supervisory scrutiny
• No generic templates. No unnecessary complexity.
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