Anti-Money Laundering (AML) checks are the ongoing compliance controls that regulated businesses, including accountancy and advisory firms, must carry out under the UK Money Laundering Regulations to identify and manage the risk of their services being used to launder money or finance terrorism. They go beyond identifying a client at the start of a relationship, covering risk assessment, ongoing monitoring and reporting obligations throughout.
How AML checks work
A firm typically begins with a firm-wide risk assessment, then applies customer due diligence at a level, standard, simplified or enhanced, matched to each client's individual risk during Client Onboarding (KYC/AML). This is not a one-off exercise: firms must monitor clients on an ongoing basis for changes in circumstances or unusual activity, keep records of the checks carried out, train staff to recognise red flags, and appoint a nominated officer, often called a Money Laundering Reporting Officer, responsible for considering whether a Suspicious Activity Report needs to be filed with the National Crime Agency.
How UK accountancy practices apply AML checks
- An accountancy practice carries out a firm-wide AML risk assessment, then applies a matching level of customer due diligence, from simplified to enhanced, based on each client's individual risk profile.
- A bookkeeping firm assigns a nominated officer responsible for receiving internal concerns and deciding whether a suspicious activity report needs to be filed with the National Crime Agency.
- A practice reviews an existing client's AML file periodically, rather than only at onboarding, to check whether their risk profile or circumstances have changed.
- An advisory firm keeps AML records for the period required under the regulations, ensuring evidence of checks carried out is available if requested by its supervisory body.
How Advantage supports AML compliance for accountancy firms
Advantage's EdgeAdvisory accelerator helps accountancy and advisory firms track client risk assessments, review dates and AML documentation within Dynamics 365, so ongoing monitoring obligations are visible and auditable rather than scattered across spreadsheets and email.
Frequently Asked Questions
Who has to carry out AML checks?
Businesses supervised under the Money Laundering Regulations must carry out AML checks, including accountants, bookkeepers, tax advisers, solicitors and a range of other regulated sectors.
Are AML checks only needed when a client is onboarded?
No. Ongoing monitoring is a legal requirement, since a client's risk profile or circumstances can change over the life of the relationship, not just at the point they are first taken on.
What happens if a firm suspects money laundering?
The firm's nominated officer must consider whether to submit a Suspicious Activity Report (SAR) to the National Crime Agency. Firms also have obligations around not tipping off the client involved once a report has been made.
