Profession-specific playbook Current
Operating playbook for US accounting firms: what genuinely applies today
There is no single unified federal AML regime for US accountants. Here is what genuinely does apply, and what to check yourself.
Some other countries run one national AML/CDD regime that directly covers accounting firms. The United States does not. This playbook sets out what genuinely applies to a US accounting firm today, and is explicit about the gap so you can confirm your own firm's state-specific obligations rather than assume a rule that doesn't exist. It is general information, not legal or compliance advice.
Action plan
1 Know that no single federal AML regime directly covers US accounting firms This is the single most important thing to get right before reading anything else in this playbook.
The United States has no equivalent of a single federal AML/CDD law that applies to accounting firms generally the way some other countries' regimes do. What genuinely applies is narrower and more specific: FinCEN's Corporate Transparency Act beneficial-ownership-reporting rule (which currently covers foreign reporting companies your firm may assist), IRS Circular 230's diligence and recordkeeping standard for practitioners before the IRS, and your own state's CPA board ethics rules. Treat those three as the real, current picture, not a single unified program.
- Don't assume a single federal AML program applies to your firm the way it might elsewhere
- Treat FinCEN CTA assistance, IRS Circular 230, and your state CPA board rules as three separate, genuine obligations
- Confirm your own state's specific requirements directly, since they are not federally unified
Done when: Your firm's compliance picture reflects the three genuine obligations below, not an assumed unified federal AML regime
FinCEN: Beneficial Ownership Information2 Track your Corporate Transparency Act beneficial-ownership assistance obligations This applies only for the specific clients whose entities remain in scope.
Under the current rule, only foreign-formed companies registered to do business in a US state or tribal jurisdiction remain reporting companies for Corporate Transparency Act purposes. Where your firm assists a client with that reporting, confirm the client entity's status first, then apply the beneficial-ownership request and verification steps this program covers.
- Confirm which of your clients' entities currently have a CTA reporting obligation
- Apply the beneficial-ownership request process only to those in-scope clients
- Recheck status periodically, since a further final rule is still expected
Done when: CTA-affected clients are identified individually, and beneficial-ownership assistance is applied only where the obligation genuinely applies
See requesting beneficial ownership information from a corporate client3 Apply Circular 230's diligence and recordkeeping standard to your practice before the IRS This is a genuine, currently enforced federal standard, distinct from any AML regime.
Circular 230, the IRS's regulations governing practice before the IRS, establishes standards of competency, diligence, and other ethical behaviour for attorneys, certified public accountants, and enrolled agents. Build documented due diligence into how your firm prepares and reviews returns and other IRS submissions, since that documentation is the practical evidence of having met the standard.
- Apply Circular 230's diligence standard to preparing, reviewing, and filing IRS submissions
- Document the basis for a position taken, not just the position itself
- Confirm which of your staff are directly subject to Circular 230's jurisdiction
Done when: Circular 230's diligence and documentation standard is being applied to IRS-facing work your firm performs
IRS: Office of Professional Responsibility and Circular 2304 Confirm your own state CPA board's ethics and recordkeeping rules State CPA board requirements fill part of the gap a single federal regime would otherwise cover, and they vary by state.
Because there is no single federal AML program for US accountants, your state's own CPA board rules on ethics, client records, and professional conduct carry real practical weight. Confirm the specific rules your state board has adopted, since they are not uniform across states, rather than assuming your firm's home-state rule applies everywhere it operates.
- Look up your own state CPA board's specific ethics and recordkeeping rules
- Check separately if your firm operates in, or serves clients in, more than one state
- Don't assume another state's published rule applies to your own practice
Done when: Your firm's practice reflects the specific ethics and recordkeeping rules your own state CPA board has adopted
Designated services
Corporate Transparency Act
Assisting a client with beneficial ownership reporting
Where a client's entity remains a reporting company under the current rule, helping them identify beneficial owners and prepare the required report is a genuine, currently applicable obligation to manage carefully.
IRS practice
Tax return preparation and representation before the IRS
Preparing, reviewing, and filing returns or other IRS submissions falls under Circular 230's diligence and recordkeeping standard, distinct from any AML framework.
State-level compliance
State CPA board ethics and recordkeeping compliance
Each state's CPA board sets its own ethics and recordkeeping rules. Confirming the specific rule your state has adopted is a genuine, real obligation, even though it isn't federally unified.