Accountancy practices
External accountants, auditors, insolvency practitioners and tax advisers are supervised by professional body supervisors overseen by the Office for Professional Body Anti-Money Laundering Supervision (OPBAS).
Where the regime bites
The Accountancy AML Supervisors Group (AASG) publishes sector-specific risk outlooks and CCAB Anti-Money Laundering Guidance for the Accountancy Sector — the HM Treasury approved interpretation of the Regulations for the sector.
OPBAS's annual Sourcebook and thematic reports set the tone for professional body supervision, and firms increasingly face inspection-level scrutiny of firm-wide risk assessment quality and client and matter-level risk assessment consistency.
What supervisors expect
Consistent CRA and MRA methodology across the firm, refreshed on trigger events, with documented rationale for departures from default risk ratings.
Verification of beneficial owners in line with Regulation 28(4), reconciled to the PSC register with discrepancy reporting under Regulation 30A.
Alertness to tax-driven ML typologies — R&D fraud, VAT missing trader, offshore structures — reflected in the firm's typologies register and staff training.
Documented decision-making for internal reports, external SARs and DAML applications, with privilege-aware handling of legal-advice work.
Recurring risk indicators
- Complex or offshore corporate structures
- Tax-abusive arrangements and R&D relief fraud
- Insolvency instructions with suspected pre-pack asset transfers
- Introduced business without evidenced source of instruction
- Non-face-to-face onboarding without compensating controls
Advisory support for the sector
- PBS inspection readiness
- Firm-wide risk assessment refresh
- CRA/MRA methodology design
- AML training and attestation