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Checklist · Internal

AML Annual Review Checklist for Accountants

Conducting your mandatory annual AML review.

Built by a practising Chartered Accountant · Unlimited users · 60-day free trial · Last updated 23 September 2026

Quick answer

AML compliance requires a firm-wide risk assessment that you must review at least annually. This checklist ensures you cover all key risk areas, update your firm's procedures, and document your findings thoroughly, as required by supervisory bodies.

Why do you need an annual AML review?

Your AML risks change as your client base and services evolve. An annual review demonstrates your commitment to compliance to supervisors.

Failing to document your annual review is a common finding during supervisory visits.

It's a proactive way to identify gaps in your firm's defences.

What should you review in your annual assessment?

Assess your firm's overall risk profile, review individual client risk levels, check staff training records, and update your firm-wide AML policy.

Key annual AML tasks

  • Firm-wide risk assessment
  • Review individual client risk scores
  • Update AML policy and procedures

+ 2 more in the full download

Checklist preview

0/4 done · showing 4 of 15 items
Firm-Wide Risk

The full 15-item checklist is in the download below. Enter your name and email to get it as a Word or PDF file.

This is a standard checklist. Each firm's requirements may vary, so please cross-check everything against current GOV.UK, Companies House and professional body guidance before relying on it.

Download the editable AML Annual Review checklist (DOCX and PDF)

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Turn this into a task and subtask template in Remindoo

Save each group as a task with subtasks, attach it to the right service and let recurring tasks create it for every client, every period. Each item gets an owner and a deadline, and nothing depends on someone remembering to print the list. See task and subtask templates.

What are the common mistakes?

  • Using an outdated firm-wide assessment
  • Failing to document the review process
  • Ignoring new guidance from your supervisor
  • Not updating training records for new staff
  • Focusing on firm-wide risk while forgetting individual client risk
“Automated reminders and task templates save countless hours each week.”
Shaz Israr, Director, BNW Accountants

Frequently asked questions

Who must do this?

Every accountancy firm under AML supervision.

How often?

At least annually, or when significant changes occur in your business.

What is the firm-wide risk assessment?

A document detailing the AML risks your firm faces based on your client base, services, and locations.

Do I need to train staff?

Yes, you must train all staff on the latest AML procedures.

Where do I store this?

Store these files securely with your firm's compliance documentation.

What if my supervisor changes?

Always stay current with the latest guidance from your specific supervisory body.

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Sources

Last updated 23 September 2026. General guidance, not regulatory advice.

Why recording AML checks properly matters

UK accountants must follow the Money Laundering Regulations and their supervisor's guidance. If a check is not recorded, supervisors will generally treat it as not done.

Evidence for your supervisor

Dated ID checks and risk assessments on each client file are what a supervisor asks to see during a review.

Consistent risk scoring

A standard risk assessment means every client is judged the same way, whoever onboarded them.

Ongoing monitoring

Reminders for periodic reviews help keep checks current rather than done once and forgotten.

Faster onboarding

Built-in digital ID and AML checks in Remindoo reduce back-and-forth with new clients.

Practical tips from UK practice

  • Complete identity checks and a risk assessment before starting chargeable work.
  • Set review dates by risk level, with higher-risk clients reviewed more often.
  • Record the reason for each risk rating, not just the rating.
  • Check your supervisor's current guidance, as requirements can change.

Written and reviewed by Waqas Sagar ACA FCCA FMAAT, Chartered Accountant with 18+ years in practice. Founder and MD of Accotax, an ICAEW, ACCA and AAT regulated London practice that has served over 5,000 clients, and founder of Remindoo. Guidance is general; check current GOV.UK and professional body guidance for your firm.

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