Country-specific guidance Current
AML operating playbook for UK accounting firms
Providing accountancy services generally puts a firm in scope, registration and supervision aren't optional extras.
UK accountancy service providers are a supervised sector in their own right under the Money Laundering Regulations. This playbook sets out what running a compliant practice actually involves, from registration through to ongoing due diligence. It is general information, not legal or compliance advice.
Action plan
1 Register for money laundering supervision, with HMRC or a professional body Supervision isn't optional if you provide accountancy services, and you only register with one supervisor.
Firms that provide accountancy services, such as bookkeeping, preparing accounts, or advising on tax, are accountancy service providers under the Money Laundering Regulations. HMRC's guidance is clear that a firm already supervised by a professional body, such as the ICAEW or ACCA, does not need to register separately with HMRC, but a firm not covered by professional-body supervision does need to register for supervision directly with HMRC.
- Confirm whether a professional body already supervises your firm for money laundering purposes
- If not, register for supervision with HMRC directly
- Don't assume professional body membership for other purposes counts as money laundering supervision
Done when: The firm's money laundering supervisor, HMRC or a professional body, has been confirmed and registration completed if required
GOV.UK: money laundering regulations, accountancy service provider registration2 Identify beneficial owners, officers, and managers for fit and proper checks Registration isn't just about the firm, the people who own and run it are checked too.
HMRC's guidance on registering for money laundering supervision requires a firm to identify its beneficial owners, officers, and managers (BOOMs) as part of the application, with certain of these individuals required to pass a fit and proper test before registration is approved. Build time for this check into your registration timeline, since HMRC's guidance notes review can take up to 45 days, and longer where more information is needed.
- Identify all beneficial owners, officers, and managers of the firm
- Allow time for HMRC's fit and proper checks as part of the registration timeline
- Keep the beneficial owner, officer, and manager list current as the firm's ownership or management changes
Done when: Beneficial owners, officers, and managers have been identified and any required fit and proper checks completed
GOV.UK: register or renew your money laundering supervision with HMRC3 Apply customer due diligence and keep records for every client relationship Supervision registration is the entry ticket, due diligence and record-keeping are the ongoing obligation.
Once registered, a firm's core ongoing obligations are the trigger points regulation 27 sets out for customer due diligence, verification from a reliable independent source, and record-keeping under regulation 40's five-year minimum. Treat these as the operating baseline for every client relationship, not a one-off registration exercise.
- Apply customer due diligence at each of regulation 27's trigger points
- Verify identity using a reliable, independent source for every client
- Keep due diligence and transaction records for the regulation 40 minimum period
Done when: Customer due diligence, verification, and record-keeping are applied consistently across client relationships, not only at registration
See UK Money Laundering Regulations client due diligence overviewDesignated services
Core accountancy services
Bookkeeping and accounts preparation
Professional bookkeeping and preparing accounts for a client are accountancy services under HMRC's own definition, and generally the starting point for confirming whether a firm needs money laundering supervision at all.
Tax services
Tax advice and tax return assistance
Giving specific tax advice or helping a client with a tax return also counts as an accountancy service under HMRC's guidance, so this work sits inside supervision even where a firm's main focus is elsewhere.
Payroll
Payroll services that include accountancy or tax advice
A payroll agent providing accountancy services or tax advice alongside payroll processing is also within scope of accountancy service provider supervision, according to HMRC's guidance, so payroll work is worth checking individually rather than assumed to sit outside it.