{"id":24490,"date":"2025-05-22T09:22:33","date_gmt":"2025-05-22T09:22:33","guid":{"rendered":"https:\/\/www.complycube.com\/?p=24490"},"modified":"2025-05-22T09:22:43","modified_gmt":"2025-05-22T09:22:43","slug":"guide-des-verifications-aml-pour-les-comptables-au-royaume-uni","status":"publish","type":"post","link":"https:\/\/www.complycube.com\/fr\/aml-checks-for-accountants-uk-a-guide\/","title":{"rendered":"Contr\u00f4les AML pour les comptables au Royaume-Uni\u00a0: guide"},"content":{"rendered":"
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TL;DR: AML checks for accountants UK<\/strong> are essential for compliance and preventing financial crime. Strong AML checks for accountants<\/strong> include due diligence, ongoing monitoring, and suspicious activity reporting. Effective AML checks<\/strong> reduce risk, protect firms, and support regulatory compliance.<\/p>\n<\/div>\n\n\n

Anti-Money Laundering (AML) screening is a significant aspect of the UK financial landscape. Particularly, this is relevant for accountants with immediate access to customers’ financial information. Screening against money laundering, fraud, and terrorist financing is a fundamental aspect in protecting businesses against exploitation for criminal purposes.<\/p>\n\n\n\n

With stringent regulations surrounding every move, accountants must exercise caution and adhere to such regulations to guarantee the healthiness of the financial system. In this guide, we\u2019ll explore the importance of AML checks for accountants UK, the key regulations to be aware of, and the steps accountants should take to ensure compliance.<\/p>\n\n\n\n

What Are AML Checks?<\/h2>\n\n\n\n

AML screening detects and discourages money laundering activities. Money laundering is making illegally obtained proceeds appear legal. It typically consists of three stages: placement (depositing illegal money), layering (concealing the illegal source of money), and integration (making the illegal money appear legal).<\/p>\n\n\n\n

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For accountants, this means they must do due diligence on their clients, their clients’ transactions, and even, in some cases, their clients’ customers, to ensure that the funds flowing through the financial system are not from crime.<\/p>\n\n\n\n

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Each firm\u2019s AML compliance<\/a> also needs to be unique.<\/span><\/p>\n<\/blockquote>\n\n\n\n

David Winch, the AML & Onboarding Adviser at MLRO Support Ltd, argues, \u201cEach accountancy firm is unique \u2013 not least because the partners in it have a unique experience, knowledge, and interests,\u201d said Winch. \u201cIn my opinion, each firm\u2019s AML compliance<\/a> also needs to be unique.\u201d For more on UK AML regulation, read \u201cAchieving Compliance: UK AML Regulation.\u201d<\/a><\/p>\n\n\n\n

Why Are AML Checks Important for Accountants?<\/h2>\n\n\n\n

Since they are gatekeepers to the financial system, accountants have an excellent opportunity to report suspicious transactions. Non-compliance with AML regulations can be extremely costly for accountants and their firms, such as hefty fines, loss of reputation, or even prosecution. In doing so, accountants are not only helping preserve the integrity of the financial system but also keeping themselves from being a passive facilitator of illicit activity.<\/p>\n\n\n\n

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UK Accountants’ Key AML Legislation<\/h2>\n\n\n\n

The UK boasts a robust anti-money laundering regime, based on a risk-based approach, and it is crucial that accountants know which specific legislation applies to their practice. Some of the key acts are:<\/p>\n\n\n\n

1. The Proceeds of Crime Act 2002 (POCA)<\/h3>\n\n\n\n

The POCA forms the basis of UK anti-money laundering. It criminalizes money laundering and establishes the obligations of UK businesses, including accountants, to report suspicious transactions.<\/p>\n\n\n\n

 2. The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017<\/h3>\n\n\n\n

These regulations, more commonly referred to as the “MLR 2017,” set the detailed requirements of the regulated business entities, i.e., accounting firms. They prescribe requirements such as Customer Due Diligence (CDD), record-keeping, and reporting of suspicious transactions.<\/p>\n\n\n\n

3. The Terrorism Act 2000<\/h3>\n\n\n\n

This legislation renders financing terrorism a crime, and accountants need to be sensitive to the possibility of clients’ terrorism finance involvement. <\/p>\n\n\n\n

4. The Criminal Finances Act 2017<\/h3>\n\n\n\n

This legislation established new corporate crime offences for the inability to prevent the facilitation of tax evasion, an additional burden on accountants and their firms. This law made important amendments to the Proceeds of Crime Act 2002, Terrorism Act 2000 and the Anti-terrorism Crime and Security Act 2001. <\/p>\n\n\n\n

The Criminal Finances Act 2017 introduces consequences that are far more severe for businesses who facilitate this criminal activity. The UK government states that, “CFA 2017 introduces corporate criminal offences<\/a> of failing to prevent tax evasion which may apply to businesses who facilitate this criminal activity. This means that businesses can be criminally liable where they fail to prevent those who act for, or on behalf of, the business from criminally facilitating tax evasion.” <\/p>\n\n\n\n

AML Obligations for Accountants<\/h2>\n\n\n\n

Accountants are required to comply with several key requirements in the UK’s anti-money laundering legislation. These include:<\/p>\n\n\n\n

1. Customer Due Diligence (CDD)<\/h3>\n\n\n\n

Before entering into a business relationship or for certain transactions, accountants will be required to conduct CDD on their customers. This involves identifying the customer, verifying their identity, and identifying their business. For high-risk customers, there is the possibility of needing enhanced due diligence (EDD).<\/p>\n\n\n\n

2. Ongoing Monitoring<\/h3>\n\n\n\n

AML rules necessitate accountants to always keep a check on their clients’ transactions to verify that they are aligned with what is known regarding the client and business. Suspicious or unusual transactions need to be identified and reported.<\/p>\n\n\n\n

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3. Record-Keeping<\/h3>\n\n\n\n

Accountants must retain their AML screening for a minimum of five years. This must include all their records on CDD, transactions, and the reports to the authorities.<\/p>\n\n\n\n

4. Suspicious Activity Reporting (SAR)<\/h3>\n\n\n\n

If there is any suspicion that an accountant’s client is involved in money laundering or terrorist financing, the accountant is required to file a SAR to the National Crime Agency (NCA). Criminal liability will be attracted if this is not done.<\/p>\n\n\n\n

5. Training and Awareness<\/h3>\n\n\n\n

Accountants must ensure their staff are regularly trained in AML procedures and comprehend what their responsibilities are to report and identify suspicious transactions. This is an essential part of building a compliance culture within the firm.<\/p>\n\n\n\n

6. Independent Audits<\/h3>\n\n\n\n

Firms need to conduct independent audits of their AML procedures to guarantee efficacy and adherence to the rules. This guarantees that loopholes within the process are addressed as soon as possible<\/p>\n\n\n

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Case Study: Weak AML Checks Led to Enforcement for Two Connected Firms<\/strong><\/h3>\n

In ICAEW\u2019s 2024\/25 AML supervision report, two connected firms were found to have serious control gaps. Reviewers identified no documented AML risk assessments, no evidence of ongoing risk review for existing clients, no Customer Due Diligence (CDD) for some new clients, outdated AML training for staff and partners, and an ineffective AML compliance review.<\/p>\n

Control Gaps from Onboarding to Ongoing Monitoring<\/strong><\/h5>\n

That means combining identity verification, sanctions and Politically Exposed Person (PEP) screening, documented CDD, periodic risk reviews, staff training, and a clear audit trail for compliance oversight. This aligns with current UK guidance, which confirms certified digital identity services can support customer due diligence under the Money Laundering Regulations, while firms remain responsible for applying broader risk checks appropriately.<\/p>\n

Solutions & Outcomes<\/strong><\/h5>\n