UK law and guidance

Anti-Money Laundering UK - Money Laundering Regulations 2017 amended by Money Laundering Regulations 2019

AML guidance  for the accountancy sector approved by HM Treasury

CCAB (The Consultative Committee of Accounting Bodies) has published new guidance for all entities providing audit, accountancy, tax advisory, insolvency or related services such as  trust and company services, by way of business.

The guidance has been updated for the new Money Laundering Regulations 2017 and

is approved by HM Treasury. It has also been adopted by the UK accountancy AML supervisory bodies. 

Click here for AML Guidance for the Accountancy Sector.

Supplementary AML guidance for Tax Practitioners approved by HM Treasury

The CCAB has published a supplementary AML Guidance for Tax Practitioners. This Guidance was approved by HM Treasury on 14 June 2019.

This supplementary guidance is not standalone but should be read in conjunction with the CCAB AML Guidance for the Accountancy Sector.

Who does this guidance apply to?

The Money Laundering Regulations 2017 apply to a ‘tax adviser’ and defines a tax adviser as:

‘a firm or sole practitioner who by way of business provides advice about the tax affairs of other persons, when providing such services’.The meaning of ‘advice’ is widely interpreted – for example tax compliance services, i.e. assisting in the completion and submission of tax returns, are included within the term.

Tax practitioners are within the scope of the Money Laundering Regulations 2017 whilst they are providing tax services by way of business. They should exercise judgement in deciding whether the provision of tax services is by way of business. If a tax practitioner decides that a service is not by way of business, they should be prepared to explain the reasons for this opinion.

CCAB AML Guidance for the Accountancy Sector

CCAB Supplementary AML Guidance for Tax Practitioners

AML Guidance for Insolvency Practitioners

CCAB has published the draft Supplementary Anti-Money Laundering Guidance for Insolvency Practitioners (IPs).  This is draft guidance pending approval from HM Treasury.

IPs should refer to the Main Body Guidance (the Guidance) for detailed information about AML legislation and associated offences, and comprehensive guidance on compliance with the various requirements imposed by the legislation.

This draft Appendix is concerned principally with matters that are particular to those acting as IPs.   This draft AML Guidance for IPs covers the UK legislation but many aspects of this guidance will also be relevant to IPs in Ireland.

Circumstances where there may be high risk of money laundering and terrorist financing

 The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (Money Laundering Regulations 2017) requires Chartered Accountants Ireland to make available any information relevant to the firm’s own firm-wide risk assessment.

We have identified a list of circumstances where there might be a high risk of money laundering or terrorist financing.  This list includes circumstances agreed by the accountancy professional body supervisors and identified by the National Risk Assessment.

Circumstances where there may be high risk of money laundering

Suspicious Activity Reports (SARs) - National Crime Agency (NCA) Guidance Documents


A SAR is a Suspicious Activity Report, a piece of information which alerts law enforcement that certain client/customer activity is in some way suspicious and might indicate money laundering or terrorist financing.

For further information, please click here for an introduction to SARs.

Click Accountancy Sector SAR Template Dec 2017 a guidance document for help when making a SAR produced by the Accountancy Sector / NCA Engagement Group 

Click UKFIU SAR Guidance Signpost Doc ( Nov 2017) - an NCA document signposting where additional SAR guidance can be found.

NCA Glossary Code and Reporting Routes

Updated UKFIU SAR Glossary Codes

The UKFIU has implemented three new SAR Glossary Codes for MLROs as a result of the increased threat posed by organised crime groups (OCGs) seeking to exploit the COVID-19 situation by means of fraud.

The Glossary Codes Note document can be found on the NCA website at the below link;

The Glossary Codes and Reporting Routes document can be found on the NCA website at the below link;

Key points

The use of glossary codes is considered good practice and will allow the UK Financial Intelligence Unit (UKFIU) and wider law enforcement to conduct analysis to identify money laundering trends, high risk cases for development and take immediate action where necessary.

The SARs regime is not a route to report crime or matters relating to immediate risks to others. The SARs regime is for reporting knowledge or suspicions of money laundering, or belief or suspicions relating to terrorist financing.

NCA Suspicious Activity Reports - Annual Reports

The UK Financial Intelligence Unit publish Suspicious Activity Reports (SARs) Annual Reports. These Report set out the factual detail of activity during the year with the headline statistic being the continued increase in the number of SARs submitted.  To view reports, please click below:

Suspicious Activity Reports Annual Report 2017
Suspicious Activity Reports Annual Report 2015

NCA Guidance on Submitting better quality SARS.

Click here for a document which aims to provide all reporters with guidance on how to submit better quality SARs to the NCA.

NCA - Confidentiality of SARs

The confidentiality of Suspicious Activity Reports is still a live issue. The Accountants Affinity Group within the Anti-Money Laundering Supervisors Forum has recently recommended that members be reminded of guidance available on this subject.

As part of this, ICAEW have kindly made available the technical release on the Confidentiality of SARs while the UK Financial Intelligence Unit (UKFIU) have recently updated its guidance on submitting a Suspicious Activity Report (SAR) within the regulated sector.

Anti-money laundering: updated guidance on financial sanctions enforcement.

The Office of Financial Sanctions Implementation (OFSI) helps to ensure that financial sanctions are properly understood, implemented and enforced in the United Kingdom. OFSI, which is a part of HM Treasury, enables financial sanctions to make the fullest possible contribution to the UK’s foreign policy and national security goals. It also helps to maintain the integrity of, and confidence, in the UK financial services sector.

The UK Government has extended powers to act against those who don’t report information that could undermine UK financial sanctions. All businesses, organisations and individuals have an obligation under financial sanctions regulations to report information which facilitates compliance. However, enforcement action could only be taken against firms or people in the regulated financial services sector who failed to report.  

The extended powers, set out in new regulations, broaden enforcement to the following business areas from 8 August 2017:

  • auditors
  • casinos
  • dealers in precious metals or stones
  • estate agents
  • external accountants
  • independent legal professionals
  • tax advisors and
  • trust or company service providers 

Prompt reporting of information is essential for financial sanctions to be an effective foreign policy and national security tool. For instance, it helps the Office of Financial Sanctions Implementation (OFSI) to detect breaches and identify those who evade sanctions by using different aliases 

The new regulations extend existing powers without creating new ones or changing the purpose of the law. The only change is that from 8 August these groups may commit a criminal offence if they do not report the information they should already be reporting to OFSI.

OFSI have updated the Guide to Financial Sanctions to help individuals and businesses understand what they should report and when. All impacted businesses are encouraged to review their responsibilities as non-compliance could lead to a monetary penalty or criminal prosecution. 

As well as new information on reporting obligations, the updated Guide clarifies OFSI’s existing positions on organisations owned or controlled by those subject to sanctions, as well as the process for obtaining a licence.

OFSI’s Guide to Financial Sanctions is published on OFSI’s GOV.UK pages:

To stay up-to-date on financial sanctions, subscribe to OFSI’s e-alert.

Alternatively, you can contact OFSI directly:

Was this article helpful?