UK HMRC has published updated money laundering supervision guidance for accountancy service providers, expanding its risk assessment and setting out 30 specific risks that firms must consider when meeting their obligations on customer due diligence, record keeping and suspicious activity reporting.
HM Revenue & Customs (HMRC) has issued updated guidance for the accountancy sector on compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The guidance applies to all accountancy service providers (ASPs) under HMRC supervision and sets out the standards firms must meet in areas such as customer due diligence, record keeping and the reporting of suspicious activity.
A key change is the inclusion of detailed guidance on risks commonly faced by ASPs. HMRC identifies 30 risks in total, covering risks common to accountancy service providers, as well as risks specific to accountancy services, bookkeeping, tax advice, payroll and audit services. These range from services that lack a clear business or economic purpose, links to high-risk third countries or overseas jurisdictions, and the use of shell companies, to risks associated with cash-intensive businesses, professional enablers, frequent changes in ownership, and customers who are secretive about their activities.
The guidance also highlights service-specific risks, including preparing accounts or returns from incomplete records, unusual borrowing activity supported by accountant references, pressure to reduce tax bills in ways that may amount to tax evasion, falsified payroll instructions, and indicators of modern slavery, human trafficking or umbrella company fraud. Audit services are flagged as higher risk where they are provided alongside other accountancy or trust and company services, as they can add legitimacy to illicit activity.
HMRC reiterates that all ASPs must carry out and document a business-wide risk assessment under regulations 18 and 18A, taking into account HMRC’s own assessment prepared under regulations 17 and 47. Firms are required to assess and manage risks relating to money laundering, terrorist financing and proliferation financing, and to keep their controls under review.
The updated guidance reflects findings from the National Risk Assessment 2025, which assessed accountancy service providers as high risk for money laundering, low risk for terrorist financing, and exposed to specific proliferation financing risks linked to the ease of setting up companies and accessing the UK financial system. HMRC emphasises that ASPs are well placed to identify suspicious activity due to their visibility over client transactions, and expects firms to use the expanded risk guidance to strengthen their policies, procedures and ongoing monitoring.
