ICAEW.com works better with JavaScript enabled.

Responsibilities and obligations of an ICAEW member firm

Helpsheets and support

Published: 02 Feb 2021 Updated: 10 Jan 2024 Update History

This section provides guidance on how ICAEW member firms can meet the obligations and responsibilities set out in the money laundering regulations.

Regulatory framework

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR17) came into force on 26 June 2017. Since then, HM Treasury has issued a number of statutory instruments to update the regulations for:

AML guidance for the accountancy sector

The Consultative Committee of Accountancy Bodies (CCAB) has published the latest version of its Anti-Money Laundering Guidance for the Accountancy Sector, together with the Tax Appendix and the Insolvency Appendix, following the Treasury’s approval of all three documents.

The guidance was initially updated in September 2020 to reflect amendments made to the UK Money Laundering and Terrorist Financing Regulations 2017 ('the 2017 Regulations'). These regulations were amended in January 2020 to reflect the Fifth Money Laundering Directive (5MLD) from the EU.

The main changes from the draft guidance are:

  • Timeframe to report PSC discrepancies reduced to within 15 working days (previously 30 days).
  • Strengthening from ‘should’ to ‘must’ for a short list of requirements.
  • Update to the legislation referenced in the guidance following the UK leaving the EU.
  • Clarified wording around enhanced due diligence for an occasional transaction where there are connections to a high-risk third country.

The CCAB also publishes a separate appendix for:

Reporting discrepancies in the People with Significant Control Register 

What is required of an ICAEW anti-money laundering (AML) supervised firm?

AML Policies and Procedures template

This template is targeted at new firms, sole practitioners and smaller firms who are looking for guidance on how to structure their AML policy and procedure documentation.

Anti-money laundering for smaller practices

Technical helpsheet issued to help new ICAEW practitioners to comply with Anti-Money Laundering (AML) legislation and guidance.

How can ICAEW firms check they comply?

ICAEW has published a compliance review checklist for firms to use to regular assess their compliance with MLR17 and associated legislation.

2021/2022 AML supervision report

Read our 2021/22 Anti-money Laundering Supervision Report for the results of our monitoring visits, the outcomes of those visits and enforcement action taken. This report also summarises all of our anti-money laundering supervisory activity during the period. Firms should pay particular attention to the most common issues we see section which includes links to resources to support compliance.

AML service

ICAEW has teamed up with SWAT UK to create a package of online systems and insightful online training seminars tailored to meet your requirements.

Criminal record checks

Under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR17) ICAEW must approve all beneficial owners, officers and managers (BOOMs) in our supervised firms.

HMRC TCSP register

Under Regulation 54 of MLR17, HMRC must maintain a register of all relevant persons who are trust or company service providers (TCSPs) that are not already registered with FCA.

UK sanctions and their role within the AML framework

The UK Sanctions Regime has been developed over the same timeframe as the AML regime and has many similar objectives and characteristics but there are also significant differences.

Criminal Finances Act – corporate offence to prevent facilitation of tax evasion

The Criminal Finances Act 2017 targets corruption, money laundering and tax evasion by aiming to recoup criminal assets and is part of the government’s strategic approach to reducing financial crime.

The Act also introduces two new criminal offenses in respect of the facilitation of tax evasion. The new offenses will be committed where a corporate entity or partnership fails to prevent an associated person from criminally facilitating the evasion of tax, whether the tax evaded is owed in the UK or in a foreign country where there is a connection to the UK.

Useful links

Please make use of the following resources to ensure you are up-to-date with the latest regulatory information and news: