The UK’s anti-money laundering (AML) landscape is undergoing a major transformation, and accountancy and bookkeeping professionals are squarely in the spotlight. With the Financial Conduct Authority (FCA) now designated as the AML supervisor for the sector, firms must prepare for rigorous, risk-weighted compliance regime.
Why the FCA’s New Role Matters
Historically, AML supervision was fragmented across multiple professional body supervisors (PBSs), such as AAT, ICAEW and ACCA. This patchwork system often led to inconsistent enforcement and regulatory blind spots. The FCA’s appointment signals a shift towards:
- Centralised oversight with clearer accountability
- Data-driven enforcement using quantitative risk models
- Stricter client due diligence (CDD) and enhanced checks for high-risk clients
This change is part of the UK’s broader Economic Crime Plan 2023–2026, aiming to close loopholes and strengthen AML controls across professional services.
What Accountants and Bookkeepers Must Do
Whether you’re a sole practitioner or part of a larger firm, the following steps are essential:
Conduct a Firm-Wide AML Risk Assessment
- Evaluate services (eg bookkeeping, company formation), client types (eg overseas ownership), and delivery channels (eg remote onboarding)
- Document and regularly update your risk profile
- Align your onboarding and monitoring processes with risk tiers
Apply Robust Customer Due Diligence (CDD)
- Verify client identity using reliable documents or electronic methods
- For businesses, scrutinise beneficial ownership and corporate structure
- Maintain ongoing monitoring and refresh ID when risk changes
Prepare for Enhanced Governance
- Expect named individuals to be held accountable for AML compliance
- Implement traceable, auditable workflows
- Train staff to identify and escalate suspicious activity
Companies House and Filing Reforms
AML compliance now intersects with corporate governance. Accountants must help clients navigate:
- Mandatory identity verification for directors
- Full digital accounts filing, including profit and loss, even for micro-entities
- Annual confirmation of lawful purpose and physical registered office addresses
These reforms aim to increase transparency and reduce abuse of corporate structures. Failure to comply could result in:
- Public enforcement actions and fines
- Loss of professional reputation
- Regulatory scrutiny of client relationships and internal controls
As one disciplinary case showed, inadequate AML procedures allowed over £9 million to pass through a firm’s account without proper documentation.
Phoenix Debola 
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