Client checks foraccountancy practices.
Check every client before you take them on, watch them every morning after, and keep the record your supervisor asks to see.
- High
- Money laundering risk for accountancy (NRA 2025)
- Daily
- Re-screening of every client
- AMLGAS
- The CCAB guidance our records follow
What the rules ask, and what we do.
From the Money Laundering Regulations 2017 and the CCAB guidance every accountancy supervisor uses.
- 01Regs 27, 28, 30
Check each client first
Identify and verify the client before you take them on, and know what the work is for.
Company clients filled in from Companies House; your client sends their own details by link. Their ID with a live selfie, by link, through Vouchsafe (on the GOV.UK register of certified services).
- 02Regs 28(4), 28(9), 30A
Find the real owners
Identify who owns or controls a company client. The Companies House register alone is not enough.
Owners traced to people from Companies House, then confirmed by your client. A difference comes with how to report it.
- 03Regs 33, 35 · sanctions rules
Screen for sanctions and PEPs
Enhanced checks for politically exposed persons. A client on a sanctions list must be reported to OFSI.
UK, UN, EU and US lists and PEPs for each client and the people behind it. You decide each possible match, with a reason.
- 04Reg 28(11)
Keep watching
Monitor every client for as long as you act for them, and keep their details up to date.
Every client re-screened every morning, company changes picked up from Companies House, and a yearly re-check reminder.
- 05Regs 18, 19 · AMLGAS 4
Assess your firm's own risk
A written firm-wide risk assessment, approved by senior management and reviewed at least yearly, with policies that follow from it.
Built from a short questionnaire using the 2025 National Risk Assessment. Policies written from it; every version kept.
- 06Regs 24, 40
Train, and keep records
Train your people, and keep due diligence records for five years after a client relationship ends.
A training log showing who is due. Every check, decision and document kept, with an audit trail and an inspection bundle.
What we check for accountants.
Every check in every plan. Yours are lit; pick another industry to compare.
Where the risk is.
The 2025 National Risk Assessment rates money laundering risk for accountancy services as high. It names these areas; our risk assessment asks about each.
- Payroll services
- Tax advice
- Bookkeeping
- Trust or company services
- Cash-intensive clients
- Seeing only part of a client's affairs
- Work through intermediaries
- Overseas PEPs
Source: HM Treasury, National Risk Assessment 2025, paragraphs 5.207 to 5.220
Asked by practices.
Do we have to check clients we already have?
Yes: at appropriate times, on a risk basis, and whenever their circumstances change (regulation 27(8)). Import your client list and run the checks, starting with the riskiest.
How often should we re-check a client?
Monitoring is ongoing for every client (regulation 28(11)), and closer for higher risk. Stratum re-screens each client every morning and reminds you to review them each year.
Is the Companies House register enough for owners?
No. You must take your own reasonable measures (regulation 28(9)) and report a material discrepancy to Companies House (regulation 30A). Stratum reads the register and asks your client to confirm it.
What happens when a client might be on a sanctions list?
You see the possible match with its listing, decide whether it is them, and record why. If it is, accountants must report it to OFSI, separately from any report to the National Crime Agency.
How long must we keep records?
Five years after the client relationship ends (regulation 40). Archived clients stay in your register with their checks, documents and history.
Who supervises us?
Your professional body (ICAEW, ACCA, AAT, ATT, CIOT, ICAS and others) or, if you have none, HMRC. All of them use the CCAB guidance (AMLGAS), which our risk assessment, policies and records follow.
Does Stratum replace our MLRO?
No. Stratum runs the checks, watches your clients and keeps the records. Your firm decides on each finding, sets each client’s risk and makes any report.
Start with your client list.
Import a spreadsheet: each client is checked once you run it, then watched every morning.