AML FAQ: 60 Questions Accountants Ask

Accountancy service providers in scope of the regulations must be supervised by an appropriate professional body or HMRC.

Yes, if the sole practitioner provides regulated accountancy services and is not supervised through another qualifying route.

It is the documented assessment of money laundering and terrorist financing risks across the firm's clients, services, delivery channels and geographies.

CDD means identifying and verifying the client and relevant beneficial owners, understanding the relationship and applying risk-based monitoring.

EDD applies in circumstances required by regulation and where the firm's risk assessment identifies a higher risk that needs enhanced measures.

No. The firm must establish and record that the relationship presents a lower risk and still carry out appropriate monitoring.

A politically exposed person is an individual entrusted with a prominent public function, with specific treatment extending to defined family members and known close associates.

No. Apply the law and current guidance proportionately, including the relevant distinction in treatment and the person's actual circumstances.

The regulations define beneficial ownership for entities and arrangements; firms must identify who ultimately owns or controls the client.

No. It is useful evidence and a cross-check, but firms must take risk-sensitive measures and resolve relevant discrepancies.

The MLRO or nominated officer receives internal reports, evaluates suspicion, manages external reporting decisions and supports the firm's AML framework.

The precise requirement depends on the firm's structure and regulations; document who performs the nominated-officer responsibilities and follow supervisor guidance.

A SAR is a report to the UK Financial Intelligence Unit within the National Crime Agency when the legal reporting threshold is met.

Tipping off concerns prohibited disclosure that may prejudice an investigation after relevant reporting; staff need clear escalation and confidentiality procedures.

Do not disclose information that could breach tipping-off or prejudicing-an-investigation provisions; seek appropriate advice where uncertain.

The regulations generally require specified CDD and transaction records for five years from the relevant end point, subject to the detailed rules and limited extensions.

Review the exact legal basis, other retention duties and any permitted extension; do not keep personal data indefinitely without a lawful reason.

Use a documented risk-based schedule and review earlier when ownership, activity, instructions or relevant circumstances change.

There is no single universal interval for every relationship; follow risk, law and your supervisor's current guidance.

It means scrutinising the relationship and relevant activity so it remains consistent with what the firm knows, including keeping CDD information current.

Keep the information considered, evidence checked, risk rationale, approvals, responsible person, dates and next action.

No. Identity verification is one part; firms also need beneficial ownership, purpose, intended nature and risk-based understanding.

No. Electronic verification can provide evidence, but the firm remains responsible for evaluating the client and resolving inconsistencies.

Yes. Remindoo records AML assessments and evidence, and runs built-in digital ID checks.

Yes. Remindoo provides built-in AML screening with continuous monitoring available, charged per check.

Yes. Firms can use recurring tasks, reminders and templates to organise review work.

Yes. Client information, documents, notes and timeline entries can be kept with the client record, subject to permissions.

No software can do that. Compliance depends on governance, risk assessment, evidence, judgement, training and action.

Remindoo does not make that claim. Compare total costs: AML risk assessment is included, and digital ID checks cost from £1 + VAT each.

[CONFIRM WITH REMINDOO TEAM]. Check the current pricing page or ask the team before relying on plan inclusion.

Include subscriptions, checks, monitoring, implementation, training, internal administration and the cost of disconnected record keeping.

Source of funds concerns the origin of money used in a particular relationship or transaction and should be understood where the risk requires it.

Source of wealth concerns how a person's overall wealth was accumulated and is often relevant to higher-risk relationships and EDD.

Apply the regulations and a risk-based approach; the nature and depth of evidence should reflect the client and circumstances.

It is supervisory review of whether the firm's policies and actual client files meet legal and supervisory expectations.

Expect firm-wide risk, policies, client files, training, governance, monitoring evidence and explanations from relevant staff.

Run a representative file review, correct gaps transparently, organise current documents and ensure staff can explain the procedure.

Outcomes vary by supervisor and facts, from no action or improvement plans to follow-up, discipline or penalties.

No. HMRC civil penalties and professional-body disciplinary regimes differ; use the relevant supervisor's current material.

Some failures and conduct can carry criminal consequences. Take legal advice on specific facts rather than relying on general guidance.

Relevant staff need appropriate, role-specific awareness of law, risk, red flags, internal reporting and data handling, with evidence retained.

Refresh when needed by risk, role, legal or guidance changes and supervisor expectations; do not rely on an arbitrary date alone.

If their work is relevant to prevention or detection, include them in an appropriate, role-specific training process.

Assessment or other evidence of understanding helps demonstrate that training was effective rather than merely attended.

It is the recorded evaluation of risk factors for a particular relationship, the overall rating, controls and review plan.

No. A risk-based system needs meaningful differentiation and a recorded rationale grounded in actual facts.

Relevant factors can include ownership complexity, geography, services, delivery channel, unusual activity and circumstances specified by law or guidance.

Treat delivery channel as one factor and apply the current regulations and guidance; do not replace holistic assessment with one label.

Complete the legally required measures, record why risk is lower and maintain proportionate ongoing monitoring.

The regulations contain timing rules and limited circumstances; do not start or continue simply for convenience. Follow exact law and supervisor guidance.

The firm may be unable to establish or continue the relationship and should consider reporting obligations without alerting the client.

Apply CDD to existing clients at appropriate times on a risk-sensitive basis and when relevant circumstances or information change.

Prioritise by risk, stop further drift, assign owners and dates, document interim decisions and escalate cases that cannot be completed.

Identify and verify the company, relevant people acting, beneficial owners and purpose, and understand ownership and control.

Investigate and resolve material inconsistencies and follow applicable discrepancy-reporting requirements and current Companies House guidance.

No. Companies House requirements and a firm's CDD duties are related but separate obligations.

Treat transfer proposals as future reform unless and until enacted and commenced. Current supervision remains in place meanwhile.

The instrument has staged commencement. Check the made SI and commencement provisions before treating any particular amendment as in force.

Start with legislation, then current government, NCA, CCAB and your own supervisor's primary guidance.

No. It is general guidance. Follow your supervisor's guidance and take appropriate legal advice on specific circumstances.