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Guide · Staff
How to Record an AML Risk Assessment for a Client
A robust risk assessment is a core requirement of UK AML regulations.
Built by a practising Chartered Accountant · Unlimited users · 60-day free trial · Last updated 23 September 2026
Quick answer
Recording an AML risk assessment involves evaluating each client against specific risk factors such as business type, location, and nature of transactions. You must document your findings, assign a risk score (e.g., Low, Medium, High), and ensure the assessment is reviewed regularly to meet your professional body's requirements and the 2017 AML Regulations.
Why is a risk assessment required?
It’s a mandatory part of the UK Anti-Money Laundering Regulations to identify potential risks.
You must be able to demonstrate your reasoning to your supervisor.
What factors should you consider?
Client background, geographic risk, service type, and transaction complexity.
Consider both 'customer' and 'service' risk levels.
How should you document your assessment?
Record clear notes on your findings and justify the final risk score you assign.
Professional judgment is key—don't just tick boxes.
See it working with your own clients
A 30-minute walkthrough using your services, deadlines and templates.
Send this from Remindoo
Save it once in Remindoo and send it from there. Store the wording as an email template, then use tokens so client names, company numbers and dates fill in automatically. Send it to one client or to a filtered group with bulk client emails. For requests that repeat, pair it with automated reminders and a recurring task so it goes out every period without anyone remembering.
What are the common mistakes?
- Generic assessments
- Failing to update annually
- Not recording the rationale
- Ignoring red flags during onboarding
“Companies House integration onboards clients in minutes; AML scoring keeps us compliant.”
Frequently asked questions
How often should I review it?
At least annually for all clients, or more frequently if their business circumstances change significantly.
What if I can't verify someone?
You must not act for them until you have satisfactory evidence. Failure to do so is a major breach of AML regulations.
Should I tell the client their score?
No. AML risk scoring is an internal compliance process and disclosing it could potentially be seen as 'tipping off'.
What is 'Simplified Due Diligence'?
It’s a lower level of checking for very low-risk clients, like public authorities, but you still need a recorded risk assessment.
How do I handle high-risk clients?
You must apply 'Enhanced Due Diligence', which involves deeper checks into their source of wealth and more frequent monitoring.
Where should I store the records?
Securely, ideally within your practice management system, ensuring they are accessible for inspection but protected from unauthorised access.
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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.
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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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