An Organisation for all
Accountants in Practice


 By CCAB Guidance for the Accountancy Sector 

  • What is money laundering?
  • What is the legal and regulatory framework?

2.1 What is money laundering?

2.1.1 Money laundering is defined very widely in UK law. It includes all forms of using or possessing criminal property (as well as facilitating the use or possession) regardless of how it was obtained.

 2.1.2 Criminal property may take any form, including:

  • Money or money’s worth
  • Securities
  • A reduction in a liability;


  • Tangible or intangible property.

Money laundering can involve the proceeds of offending in the UK but also of conduct overseas that would have been an offence had it taken place in the UK. There is no need for the proceeds to pass through the UK. For the purposes of this guidance money laundering also includes terrorist financing. There are no materiality or de minimis exceptions to money laundering or terrorist financing 

(MLTF) offences.

 2.1.3 Money laundering activity can include:

  • A single act (for example, possessing the proceeds of one’s own


  • Complex and sophisticated schemes involving multiple parties;
  • Multiple methods of handling and transferring criminal property; or
  • Concealing criminal property or entering into arrangements to assist others to conceal criminal property.

 2.1.4 Businesses need to be alert to the risks posed by:

  • Clients;
  • Suppliers;
  • Employees;


  • The customers, suppliers, employees and associates of clients.

2.1.5 Neither the business nor its client needs to have been party to money laundering for a reporting obligation to arise