This year's results demonstrate the positive impact of our supervisory work, with 84.5% of firms assessed as compliant or generally compliant and all the SARs we reviewed were of good quality.
Firm-wide risk assessments
Firms must assess the money laundering risks they face, considering factors such as their clients, jurisdictions and services. We found that some firms had not fully assessed or documented the risks they faced.
Customer due diligence
Firms must identify their clients, understand their business and carry out appropriate customer (or client) due diligence (CDD). We found that some firms had not completed adequate CDD for new clients or kept client information up to date throughout the relationship.
AML policies and procedures
Firms must have effective anti-money laundering policies and procedures that reflect the nature and size of their business and the money laundering risks they face. These should be documented, tailored to the firm’s circumstances and regularly reviewed to ensure they remain effective.
AML training
Firms must ensure relevant employees receive appropriate and effective anti-money laundering training so they understand their responsibilities and can identify and prevent money laundering. We found that some firms had not provided sufficient training or ensured it was effective, contributing to non-compliance in other areas.
Verification and reporting
Firms must carry out verification procedures that address identified risks and report relevant discrepancies in the People with Significant Control Register. We found that some firms had not gathered sufficient evidence to mitigate risks or reported material discrepancies to Companies House.
Anti-money laundering supervision report
Read the 2025/26 AML Supervision Report to find out about ICAEW’s supervisory activity.
