The regulations
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) set the duties: a firm-wide risk assessment, policies and controls, customer due diligence, record keeping and reporting. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621) came into force on 30 June 2026. Among other changes, they replaced euro thresholds with sterling: the occasional transaction threshold in regulation 27(2) is now £12,000.
Customer due diligence has its own guide: client due diligence.
Who supervises an accountancy practice
GOV.UK lists the professional bodies that supervise their own members, including ACCA, ICAEW, ICAI, ICAS, the Institute of Accountants and Bookkeepers, CIMA and AAT. An accountancy service provider that is not supervised by a professional body must register with HMRC. GOV.UK states that trading while not registered is a criminal offence.
Being supervised by a body depends on that body's rules. ACCA's factsheet Am I in public practice? (issued 23 June 2026) says members who provide bookkeeping outside its definition of public practice are still subject to anti-money laundering supervision, and must either obtain an ACCA practising certificate to be supervised by ACCA or register with HMRC or another recognised body.
HMRC registration and fees
- Registration fee
- £300, one-off and non-refundable (GOV.UK: fees)
- Premises fee
- £400 for each premises on the application
- Annual declaration fee
- £400 for each premises, paid each year
- Approval check
- £40 for each beneficial owner, officer or manager tested, non-refundable
- Processing time
- Up to 45 days for a new application (GOV.UK: register or renew)
Registering with HMRC
Assess the risks
Before applying, HMRC requires a risk assessment covering money laundering, terrorist financing and proliferation financing, and policies, controls and procedures to manage those risks.
Apply online
Use HMRC's online service to apply, update the registration and manage the account.
Pay the approval check
Each beneficial owner, officer or manager is tested once. Someone who has paid the £40 approval check before can say so on the application (GOV.UK).
Renew each year
Registered businesses submit an annual declaration that their details are correct and pay the annual fee (GOV.UK).
OPBAS and the move to FCA supervision
The Office for Professional Body Anti-Money Laundering Supervision (OPBAS) sits within the FCA. It was set up in 2017 under the OPBAS Regulations 2017 to oversee the professional bodies that supervise the accountancy and legal sectors (FCA: OPBAS). OPBAS supervises the bodies. It does not supervise individual firms.
The government has decided that the FCA will take over anti-money laundering supervision of accountancy service providers, legal service providers and trust and company service providers. The FCA's reform page, published on 22 September 2026, says the key legal changes are in legislation going through Parliament, that it does not expect to begin supervision until autumn 2028, and that the transition is likely to run in phases and finish around 2030. For now, nothing changes: firms keep their current supervisor and processes.
Suspicious activity reports
People working in the regulated sector must disclose knowledge or suspicion of money laundering or terrorist financing. Staff report internally to the practice's nominated officer, who decides whether to report to the National Crime Agency (HMRC AMLG11100).
Reports go through the NCA's SAR Portal. Where the practice needs a defence against money laundering before going ahead with a transaction, the nominated officer asks the UK Financial Intelligence Unit first, and a 7 working day notice period applies (HMRC AMLG11100). The portal does not keep a copy, so the practice keeps its own copy of every report and a note of decisions not to report.
Saying anything that could prejudice an investigation is the tipping off offence, with a penalty of up to five years' imprisonment (HMRC AMLG11100). ICAEW's Code of Ethics (R320.7B) forbids an outgoing accountant from telling an incoming one that a report has been made.
Questions
How long must anti-money laundering records be kept?
Regulation 40 requires due diligence documents and transaction records to be kept for five years from the date the business relationship ends, or the occasional transaction completes. Transaction records within a relationship need not be kept for more than 10 years. Personal data must then be deleted, unless the law requires it to be kept, the person consents, or it is needed for legal proceedings.
Can a practice register for an agent services account before supervision is approved?
No. HMRC rejects an agent services account application where anti-money laundering supervision has been applied for and not yet approved. See the HMRC agent services account.
Where is HMRC's guidance for supervised businesses?
HMRC's manual anti-money laundering guidance for supervised businesses covers due diligence, reporting and record keeping, with a sector risk assessment for accountancy service providers at AMLG3700.
In Accountin
Accountin's audit log records invitations, role changes, approvals, exports and filings by person and date, and clients can send documents to the practice through the client portal.
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