How ICPA’s Anti-Money Laundering Procedures Pack Keeps Accountants Compliant

Accounting practices are on the frontline in the fight against financial crime. Under the UK’s 2017 Money Laundering Regulations (MLR 2017), firms must implement strict anti-money laundering (AML) procedures to prevent (and report) financial crimes. Compliance isn’t necessarily easy, though – HMRC’s guidance evolves frequently and keeping up can be time-consuming for small practices with limited resources.

It’s a legal obligation with serious ramifications, but through our partnership with The HAT Group, ICPA does offer support in the form of the Anti-Money Laundering Procedures Pack. It can be arduous for small practices to manage day-to-day work alongside completing risk assessments, maintaining airtight documentation, and ensuring staff are trained, especially without a dedicated compliance team. The procedures pack is a comprehensive resource to help you meet AML obligations.

From risk assessments to due diligence checks to reporting mechanisms, these procedures protect you from legal penalties, reputational damage, and criminal prosecution – while maintaining trust with your clients and regulatory bodies. Instead of spending hours deciphering regulations and building processes from scratch, ICPA members can rely on ready-made, HMRC-compliant templates, risk assessment tools, internal reporting forms, and step-by-step guidance.

The Importance of AML Compliance for Accountants

As professionals working at the heart of the UK’s financial system, accountants play a vital role in protecting that system from abuse. As the supervisory authority for many accountancy firms, HMRC expects practices to have a clear, practical system for managing money laundering risks. Similarly, the Consultative Committee of Accountancy Bodies (CCAB) issues detailed guidance to help firms apply these regulations in a way that’s proportionate and effective.

The MLR 2017 apply to all accountancy practices – large or small. Firms must have clear, documented procedures for identifying and assessing risk, verifying client identities, and reporting suspicious activity. With increasing scrutiny from supervisory bodies, there’s no room for gaps in compliance. Falling short of the regulatory requirements can lead to civil penalties (including fines) or even criminal sanctions for both firms and individuals in senior positions.

The ICPA Anti-Money Laundering Procedures Pack gives your firm everything you need to take a confident, professional approach to compliance.

Compliance with HMRC and CCAB Best Practices

HMRC AML guidance is clear: accountants must take proactive steps to ensure their services aren’t exploited for criminal activities. The CCAB’s guidance helps practices interpret and apply these rules, outlining what you need to do to comply with UK legislation.

If you provide any service involving the recording, review, calculation, or reporting of financial information, you’re likely within scope. To comply, firms must implement internal systems and controls that assess client risk, perform due diligence, monitor clients on an ongoing basis, and ensure staff can raise internal suspicious activity reports (SARs) where appropriate. Policies must also cover record keeping, training, compliance management, and communication. These procedures should be tailored to the size and nature of your business and reviewed regularly.

Senior management is accountable for ensuring these systems are fit for purpose. The practice’s Money Laundering Reporting Officer (MLRO) plays a central role. The MLRO maintains oversight of risk assessments, internal reporting systems, and the effectiveness of AML controls. They must assign clear responsibilities, maintain documentation, and ensure relevant staff understand their AML obligations through regular, role-appropriate training.

Required policies, controls and procedures

Policies and procedures to counter MLTF must be implemented (and documented). These internal controls need to be proportionate to the size and complexity of the firm and cover the following:

• Risk-based approach and management
• Customer Due Diligence (CDD)
• Suspicious activity reporting
• Record keeping
• Training staff on AML responsibilities.

Policies must be regularly reviewed and updated, with written evidence of this process. Anti-money laundering compliance isn’t just about having the right policies on paper – it’s about embedding them into your daily work.

Inside the ICPA Anti-Money Laundering Procedures Pack

The Anti-Money Laundering Procedures Pack is designed to align with CCAB and HMRC AML guidance, ensuring you can implement best practices with minimal complexity. The guide sets out the key compliance objectives and outlines who holds responsibility within your firm for AML compliance. It ensures everyone understands their role and what’s expected of them.

Firm-wide risk assessment

All firms are required to assess and manage money laundering and terrorist financing (MLTF) risk through a documented, risk-based approach. You’re expected to evaluate risks associated with your business model, client base, and service offerings. Annual assessments are expected at a minimum, with updates triggered by emerging risks.

In the procedures pack, you can access an Annual Compliance Review Pack containing your Practice-Wide Risk Assessment. This document should be completed first, as it directly informs how you tailor your AML procedures to your firm’s specific structure and risk profile. A step-by-step guide is included to customise the documents appropriately.

Individual client risk assessments

Every client presents a different level of AML risk, making individual risk assessments essential. The ICPA Anti-Money Laundering Procedures Pack provides easy-to-use templates for evaluating:

• Client identity and verification (IDV) requirements
• Source of funds and business legitimacy
• Geographical risk factors
• High-risk transactions or unusual activities.

A practical suite of forms and checklists to help you record your understanding of each client, conduct a documented risk assessment, and gather the evidence needed to verify identities, including beneficial owners where required. Multiple versions of the CDD forms are provided so you can select the most appropriate one based on the complexity or risk level of the client.

For consistency, we recommend completing the CDD forms for all clients – even existing ones – unless your previous documentation meets the current regulatory standards. Each CDD form includes a built-in annual review grid to support ongoing compliance. Unless there’s a significant change in the client’s profile, you won’t need to complete a new form each year.

Internal reporting forms

Firms have a legal obligation to report knowledge or suspicion of money laundering, and clear procedures for reporting suspicious activity are a must. The MLRO is expected to train staff to recognise suspicious activity and ensure they know how to escalate concerns internally.

The Anti-Money Laundering Procedures Pack includes an internal reporting form for staff to raise suspicions with the MLRO. It also provides a framework for the MLRO to record their decisions, including whether a report to the National Crime Agency (NCA) is necessary. These forms help firms build a defensible internal reporting framework, reducing liability and showing regulators that you take your responsibilities seriously.

Record keeping

All documents can be stored electronically, provided they’re secure and accessible. If you’re using an online verification provider, you’re not required to keep paper documents, though you may need copies of key identification details to support reliable verification.

Key Benefits of ICPA’s Anti-Money Laundering Procedures Pack

HMRC and CCAB expect firms to understand the risks specific to their services and clients, and to tailor their policies and procedures accordingly. The ICPA Anti-Money Laundering Procedures Pack has been built around these expectations.

Practical support for small practices

Big firms often have in-house compliance teams – small practices usually don’t. The AML Procedures Pack is designed with smaller firms in mind. Even with limited resources, compliance becomes more manageable with the right tools. The procedures pack gives you ready-to-use templates without the stress of building systems from scratch – you can focus on reviewing and applying what’s already been built around the HMRC and CCAB’s gold standard.

Simplified compliance guidance

The ICPA AML procedures pack includes a straightforward guide that helps practices identify which elements are relevant without unnecessary administrative burden. This ensures small firms:

Focus on AML requirements applicable to their size and structure
Allocate time and resources effectively
Respond appropriately to high-risk scenarios
Are ready for HMRC reviews and supervisory checks.

Confidence for HMRC audits

HMRC audits can be stressful, but ICPA’s Anti-Money Laundering Procedures Pack helps accountants stay compliant and prepared. With access to the pack’s compliance records, risk assessments, and reporting tools, you can ensure you collect and document the necessary due diligence information to meet HMRC expectations.

Streamlined procedures and reporting

The ICPA AML pack translates complex regulatory expectations into practical, usable templates and guidance. A well-designed, practical framework reduces the time and stress involved in meeting your legal obligations and helps ensure nothing is missed.

From recognising when enhanced due diligence is required to keeping accurate records, and being prepared for supervisory checks or audits, the ICPA Anti-Money Laundering Procedures Pack provides a straightforward, structured approach to AML compliance for accountants. ICPA members get exclusive access to an invaluable resource. To learn more about ICPA membership options or access the pack, contact the ICPA team today.