AML policy template for UK accountancy practices

1. Introduction and scope

This policy sets out the anti-money laundering (AML) and counter-terrorist financing (CTF) procedures for [Practice Name]. It applies to all partners, directors, employees, and contractors involved in the provision of regulated accountancy services. This policy is maintained in accordance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended).

2. Firm-wide risk assessment

[Practice Name] has completed a firm-wide risk assessment that considers: the types of clients we serve; the services we provide; the geographic markets in which our clients operate; the delivery channels through which we interact with clients. Our risk assessment is reviewed at least annually and updated following any significant changes to our practice or client base.

[Insert summary of your firm's risk level and key risk factors here.]

3. Customer due diligence (CDD)

We apply CDD to all clients before commencing a business relationship or carrying out an occasional transaction above the relevant threshold. Our standard CDD includes: verification of the client's identity using a current government-issued photo ID and proof of address dated within the last three months; for corporate clients, identification of beneficial owners with more than 25% ownership or control; an initial assessment of the client's risk level.

[Add any additional CDD steps specific to your practice here.]

4. Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence in the following circumstances: the client is a Politically Exposed Person (PEP) or is closely associated with a PEP; the client is from or operates in a high-risk jurisdiction; the transaction or business relationship is unusual, complex, or high-value with no apparent legitimate purpose; any other circumstances that suggest higher money laundering risk.

EDD includes: additional verification of the client's identity and background; investigation of the source of funds and source of wealth; senior management approval before commencing the business relationship.

[Add practice-specific EDD triggers here.]

5. PEP and sanctions screening

All clients are screened against PEP lists and international sanctions lists at onboarding and [state your ongoing monitoring frequency]. We use [name your screening tool or describe your manual process]. Where a match is identified, we [describe your escalation procedure]. Results of all screening are recorded and retained for a minimum of five years.

6. Record keeping and retention

We retain the following records for a minimum of five years from the date on which the business relationship ends or the transaction is completed: copies of identity verification documents; copies of any other documents obtained during CDD; supporting evidence for risk decisions; screening results; any notes relating to suspicious activity.

Records are stored [describe your storage method — paper, electronic, or both] and are accessible within [state your retrieval time, e.g. 48 hours] upon request.

7. MLRO appointment and responsibilities

The Money Laundering Reporting Officer (MLRO) for [Practice Name] is [MLRO Name], [Job Title]. The MLRO is responsible for: receiving internal reports of suspicious activity; deciding whether to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA); maintaining this AML policy and ensuring it is reviewed annually; overseeing the firm's AML training programme; acting as the primary point of contact for HMRC AML supervision. The MLRO has the authority to decline to proceed with a transaction or business relationship where money laundering concerns cannot be resolved.

8. Staff training

All partners and relevant staff receive AML training at least once every [12 months / 24 months]. Training covers: the legal requirements under the MLR 2017; how to identify suspicious activity; our CDD procedures; how to make an internal suspicious activity report; the consequences of tipping off. Training records are maintained by [name/role] and are available for inspection.

9. Reporting suspicious activity

Where a partner or staff member suspects that a client or transaction may be connected to money laundering or terrorist financing, they must report this to the MLRO immediately using [describe your internal reporting method]. The MLRO will review the report and decide whether to submit a SAR to the NCA. Under no circumstances should a client be informed that they are under suspicion (tipping off).

10. Policy review

This policy is reviewed at least annually by the MLRO and updated to reflect any changes to: relevant legislation or HMRC guidance; the practice's client base or services; findings from HMRC supervision visits or internal reviews. The current version of this policy supersedes all previous versions.