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AML Supervision

Safeguard Your Business

Accountants are key gatekeepers of the financial system, facilitating transactions that support the economy. With this responsibility comes a duty to ensure your services are not misused for criminal purposes.

AIA is an approved supervisory body under the Money Laundering Regulations 2017 (amended 2019), where AIA is listed in schedule 1 as an approved supervisory body. In the Republic of Ireland AIA is a designated body under the Criminal Justice (Money Laundering and Terrorist Financing)(Amendment) Act 2018 and SI No. 578/2019 – European Union (Money Laundering and Terrorist Financing) Regulations 2019.

These regulations require firms and individuals providing accountancy, tax, audit, insolvency, or trust and company services to take proportionate steps to deter, detect, and disrupt money laundering and terrorist financing.

If you offer accountancy services, you must be supervised by an approved body and operating without supervision is a criminal offence.

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Monitoring and Supervision

AIA takes a risk-based approach to anti-money laundering (AML) supervision, ensuring that members in public practice meet their legal and professional obligations.

When you apply for a Practising Certificate, you agree to participate in AIA’s Quality Assurance and Practice Monitoring programme. This process helps confirm that your firm understands and has implemented the key requirements of the Money Laundering Regulations, as well as AIA’s Constitution and Public Practice Regulations.

As part of our quality assurance framework, AIA conducts regular monitoring visits carried out by trained reviewers. These reviews are designed to:

Assess your compliance with AML and professional standards
Ensure you have appropriate policies, procedures, and controls in place
Support continuous improvement and best practice in your firm

Monitoring is not just about meeting regulatory requirements—it’s about safeguarding your business, your clients, and the reputation of the profession.

Register for AML Supervision

Under the Money Laundering Regulations 2017 (amended 2019), any firm or individual providing accountancy, tax, audit, insolvency, or trust and company services must be supervised for AML compliance by a recognised supervisory authority.

AIA is listed in Schedule 1 of MLR2017 as an approved professional body supervisor. In the Republic of Ireland, AIA is a designated body under the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018 and S.I. No. 578/2019.

Who AIA Supervises

AIA automatically supervises members who hold a Practising Certificate, unless they are confirmed to be supervised by another professional body.
Members providing trust or company services as part of their accountancy practice are supervised by AIA for all their work.
In cases where a member operates within a group structure, and subsidiaries are authorised under the Financial Services and Markets Act for FCA-regulated activities, AIA supervises the non-FCA regulated work.

If your firm operates in a business sector covered by MLR2017 and is not already supervised by a professional body or the FCA, you must register for supervision. HMRC provides further guidance and registration support for firms not covered by a professional body.

Use a flowchart to identify the correct supervisory authority for your firm.

Make a Membership and Practising Certificate Application.

Guidance and Support

Whether or not you’re a member of a recognised professional body, if you provide audit, accountancy, tax, insolvency, or trust and company services in the UK, you must comply with anti-money laundering (AML) regulations. Clear, practical guidance is essential to help you meet these obligations with confidence.

How AIA Supports You

AIA offers comprehensive AML guidance and resources to help supervised firms stay compliant and protect their business. Our support covers:

Firm-wide risk assessments
Internal controls and procedures
Client due diligence, including simplified and enhanced checks
Training and staff awareness
Criminal record checks
Handling politically exposed persons (PEPs)
Third-party reliance
Record keeping and data protection
Trust and company service provision (TCSP)

Additional Resources

We also provide:

Guidance on submitting Suspicious Activity Reports (SARs)
Events and online courses focused on AML compliance
Templates and checklists to support day-to-day compliance
Updates on emerging risks and regulatory changes
Access to discounted AML compliance software

AIA’s guidance is designed to be practical, up to date, and easy to apply—helping you meet your obligations and uphold the highest standards of professional conduct.

TCSPs Supervision

Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR2017), any business acting as a trust or company service provider (TCSP) in the UK must be registered with HMRC, unless already supervised by the Financial Conduct Authority (FCA) or another approved body.

Firms that are not registered are not permitted to carry out TCSP work under MLR2017.

What is a TCSP?

A TCSP is any firm or sole practitioner whose business involves:

Forming companies or other legal entities.
Providing registered offices, business or correspondence addresses.
Acting or arranging for someone to act as:
- Director or secretary of a company.
- Partner in a legal entity.
- Trustee of an express trust.
- Nominee shareholder (unless for a listed company).

Even if these services are offered occasionally or alongside other accountancy services, the provider is still considered a TCSP and must be registered

HMRC’s TCSP Register

To maintain the national TCSP register, HMRC has asked AIA and other professional body supervisors to report firms under their supervision that perform TCSP work.

AIA submits firm details based on your firm return, including:

Your firm’s name (or your name if you’re a sole practitioner).
Registered address.
Confirmation that beneficial owners, officers, and managers are fit and proper.

Strengthen AML Compliance in Your Firm

Beneficial Owners, Officers and Managers

AIA must check that supervised firms comply with Regulation 26 and that all beneficial owners, officers and managers (BOOMs) do not have a relevant criminal conviction.

AIA is only able to approve a BOOM if a valid DBS certificate has been reviewed.

Every newly appointed BOOM must obtain a DBS certificate at the time they become a BOOM and AIA must receive a notification of any appointment along with a copy of the valid DBS certificate. An individual cannot act as a BOOM within the practice without AIA authorisation.

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AML Compliance Software

Accountancy firms supervised by AIA under the Money Laundering Regulations must have robust policies and procedures in place, appropriate to the individual firm’s needs, to ensure anti-money laundering compliance and AIA is pleased to offer access to AMLCC for a discounted charge to AIA Members in Practice.

AMLCC subscription provides firms with the essential tools needed to assess their clients through online reporting and record keeping as well as train their staff, this in turn gives reassurance to the AIA that AIA registered firms are meeting their statutory obligations and incorporating best practice into their work.

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Whistleblowing

If you come across an accountancy service provider (ASP) or trust and company service provider (TCSP) that does not appear to be regulated under the Money Laundering Regulations 2017 or appears to be ignoring the regulations, and you want to report it confidentially, you can do one of the following:

contact their anti-money laundering supervisor
if their supervisor is AIA, you can report this to us confidentially at aml@aiaworldwide.com or by calling 0191 493 0269
if AIA is not their AML supervisor, you should contact the relevant supervisory body.
contact the MLR Central Intervention Team at MLRCIT@hmrc.gov.uk

If you come across an accountancy firm or trust and company service provider that is supervised by AIA and appears to be ignoring the regulations, you can report it confidentiality to us.

Working in the Public Interest

As an approved supervisory body under the MLR2017 AIA is regulated by the Office for Professional Body Anti-Money Laundering Supervision (OPBAS). OPBAS is a regulator set up by the government to strengthen the UK’s AML supervisory regime and ensure the professional body AML supervisors provide consistently high standards of AML supervision.

Accountancy AML Supervisors' Group

AIA also works in the public interest as part of the Accountancy AML Supervisors’ Group (AASG) working closely with HM Treasury, the Home Office and the National Crime Agency to represent members’ views and to communicate up-to-date information and guidance back to you. The AASG is a sub committee of the UK Anti-Money Laundering Supervisors Forum (AMLSF), a forum in which professional bodies work collaboratively to develop supervisory policy to promote consistency in standards and best practice and receive AML intelligence from law enforcement agencies and the government.

ISEWG Logo

AIA works in collaboration with law enforcement agencies, regulators and other professional body supervisors to share intelligence and actively combat money laundering and terrorist financing through the Accountancy Sector Intelligence Sharing Expert Group (ISEWG).

AIA is also a signatory to the Joint Fraud Taskforce Accountancy Charter which is a voluntary agreement between law enforcement, professional supervisory bodies and government to better understand and tackle fraud. One of its long-term goals is to produce a fraud toolkit which includes advice and guidance to accountants on current fraud risks, checks they can undertake to help identify potential frauds and where to signpost victims to for support.

Annual AML Supervisory Activity Reports

Thematic Reviews

Thematic Review into AML Supervised Members in Practice acting as Trust or Company Service Providers (TCSPs)