As previously explained by ICAEW’s Tax Faculty, HMRC does periodically ask tax agents to confirm who supervises them for money laundering if they are not registered with HMRC.
HMRC asks the public to report those businesses that they believe should be AML-supervised but aren’t. Businesses can check HMRC’s supervised business register but remember that HMRC’s register will not include firms supervised by their professional body.
ICAEW member firms are automatically subject to Practice Assurance and money laundering supervision by ICAEW. ICAEW supervises around 11,000 firms. All firms should check that they know who their supervisor is and, if they believe it is ICAEW, they should check the ICAEW member firm definition.
Where an accounting firm is not supervised by a professional body, HMRC is the money laundering supervisory body and such businesses need to register with HMRC.
In addition to ICAEW, the following accounting bodies are listed as supervisory authorities for accounting firms (see Schedule 1 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017):
- Association of Accounting Technicians
- Association of Chartered Certified Accountants
- Association of International Accountants
- Association of Taxation Technicians
- Chartered Institute of Management Accountants
- Chartered Institute of Taxation
- Institute of Certified Bookkeepers
- Institute of Chartered Accountants in Ireland
- Institute of Chartered Accountants of Scotland
- Institute of Financial Accountants
- International Association of Bookkeepers