AML news

The Economic Crime & Corporate Transparency Act (ECCTA) 2023 received Royal Assent on 26 October 2023, and the provisions of the Act are starting to be implemented. The primary aims of the ECCTA are to enhance corporate transparency and reduce economic crime, therefore providing increased benefit to the UK economy, for both businesses, and individuals. To facilitate these aims, the Act implements provisions about companies, limited partnerships and other corporate entities, including the registration of overseas entities and the individuals associated with them. As part of implementation of the Act, Companies House will have new and enhanced powers to improve the quality of the information held on the Companies Register. Companies and individuals will also be required to comply with their obligations to deliver documentation on time and in the correct format. A number of the changes are being implemented from March 2024; these are outlined below. The changes will apply to incorporated entities, limited partnerships and limited liability partnerships. It will also apply to their members and directors. Companies House has set out the following important changes:  • Appropriate registered postal and email addresses – Companies will need to ensure their registered office address is “appropriate”, meaning that any document delivered to that address would be reasonably expected to come to the attention of a person acting on behalf of the company, and acknowledgement of delivery can be provided. For these reasons, PO Boxes will no longer be permitted as registered office addresses. Companies will also need to supply an appropriate email address with their next confirmation statement. As part of the transition, we understand Companies House will communicate to companies both by post and by email, with an eventual move to email-only communication. • Lawful purpose – On incorporation, the subscribers (the members of the entity at point of incorporation) will need to make a statement that the entity is being formed for a lawful purpose. A similar statement will be required for all entities on their next confirmation statement, confirming that all intended future activities are lawful. • Greater powers for Companies House – The Registrar will have enhanced powers to scrutinise, query and reject information it believes to be incorrect or inconsistent with information already held on the Register. In some cases, the Registrar will have the power to remove previously filed information. Annotations will also be made public on the Register to make stakeholders aware of potential issues with information supplied. • Enforcement and sanctions – Companies House will be given greater power to take action where a company, and its directors, do not respond to formal requests for information, or where their registered office is not an appropriate address. Sanctions could include financial penalties, annotations on the company’s public record, or even in the most severe cases prosecution. In addition to the above, Companies House will be closing their Belfast office to the public from 4 March 2024. Therefore, filing paper documents, including financial statements and confirmation statements in person will not be possible at the Belfast office from that date. Individuals wishing to file information in paper format will need to post the documents to the Registrar’s office in Cardiff. Electronic filing options are available for almost all documents, and Companies House are encouraging companies to avail of these filing options, as they phase out paper filings. Further information on the remaining significant changes, such as the identity verification requirements and changes in filing options, will be available in the coming months from Companies House. Article written by Maeve Hunt, Principal – Head of Accounting Services Grant Thornton (NI) LLP and Chair of the Members in Practice Committee. Originally published in Practice News February 2024. The opinions expressed are solely those of the writer and not to be construed as those of the Institute. The purpose of technical articles is solely to draw the attention of the reader to issues, and these should never be construed as guidance or relied on. To the fullest extent permitted by law, no liability is accepted by the Institute or the author for persons acting or failing to act as a result of anything contained in this article.  This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.

Economic Crime and Corporate Transparency Act 2023 Just published see our short guide on the UK’s Economic Crime and Corporate Transparency Act 2023.The guide details some of the changes which will be brought about by the Act. 

The UK Money Laundering and Terrorist Financing (Amendment) Regulations 2023 (Regulation 1371/2023) which took effect on 10 January 2024, provides that for the purpose of assessing risk, the starting point is that domestic (i.e.UK) PEPs present a lower level of risk than non-domestic PEPs .If no enhanced risk factors are present, the extent of enhanced customer due diligence measures to be applied in relation to that customer or potential customer is less than the extent to be applied in the case of a non-domestic PEP. A parliamentary statement on lower risk of domestic PEPs explains the change is to ensure that relevant persons take a proportionate and risk-based approach to the treatment of domestic PEPs, and to allay concerns that a number of holders of prominent public positions and their family have encountered problems accessing financial services due to their status as Politically Exposed Persons. This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.    

From the Professional Accountancy team…... Readers may find interesting the content of the CBI s first edition of CBI Financial Crime Bulletin following on from the previous AML Bulletin series. The bulletin was published in December 2025. It deals with areas such as risk assessments referencing Ireland’s AML National Risk Assessment which is currently being updated and hopefully will be published this year. It also deals with crypto, fraud and scams ,financial sanctions and EU AML developments with AMLA now up and running  .   This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.    

From the Professional Accountancy team…... In December 2025 the European Commission announced planned changes to the list of high-risk jurisdictions .Russia was added to the list in order to strengthen the international fight against financial crime. In addition, updates were also announced for the high-risk jurisdictions list following the decisions taken at the FATF and its list of ‘Jurisdictions under Increased Monitoring’ (‘grey list’), following the FATF Plenaries of June and October 2025. The EU has added new third-country jurisdictions to the list (Bolivia and the British Virgin Islands) and delisted a number of others (Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania). The changes will not enter into force until published in the Official Journal.  For further information regarding the planned changes to the list of high-risk jurisdictions, please refer to European Commission webpage on high risk third countries . This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.

In December 2025 the Institute published Technical Alert TA 05/2025 - Outline of selected changes under the European Union 6th Anti Money Laundering Package. The Alert provides a high-level outline of some of the changes which will occur when AMLD6 comes into force in 2027.Readers can read a news item on Technical Alert TA05/2025 and the changes here . The Professional Accounting team has now updated our Technical Hub to include links to the Technical Alert , the December news item on the alert and some links to Accountancy Europe resources on AMLA and AMLD 6 .   This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.  

From the Professional  Accounting team … Members and readers may be aware that the European Anti Money Laundering Authority (AMLA) commenced its work this year. Part of its remit is to provide regulatory technical standards (RTSs) and guidelines for both financial and non-financial obliged entities on areas dealt with in the AML Regulation and AML Directive, the European Union 6th Anti-Money laundering package, informally known as AMLD6. These laws were passed in 2024 but most of the provisions do not come into force until 2027. The provisions apply to all obliged entities including accountants, auditors, and tax advisors. As AMLA’s work continues over the coming years (throughout 2026 and 2027), the Institute will monitor and distribute more information and guidance of interest and importance to members in the anti-money laundering area. In the meantime, we have prepared Technical Alert 05/2025, which outlines selected changes to current AML law under AMLD6. The Alert provides a high-level outline of some of the changes which will occur when AMLD6 comes into force in 2027. While this seems like a relatively long time away, it will pay to gain an early insight and understanding of the changes prior to provisions coming into force. The Alert highlights differences from current law, which are likely to be of most relevance or interest to our members. It is a comparison document rather than specific or detailed instructions or guidance on AMLD6. Nonetheless, we hope that it will provide some useful information for our members in gaining further understanding of the new compliance requirements under the AMLD6 package. Some of the changes, which members should take note of include: More detailed requirements for customer due diligence (CDD) procedures. EU Ban on cash payments over €10,000. Individual member states may set even lower limits. More closely defined AML roles, governance structures, and internal control framework. An independent audit function within entities or the possibility to outsource this to an external expert. This may pose challenges for sole practitioners, and it is going to be an additional cost of being in practice (where independent audit functions do not currently exist). New outsourcing rules and outsourcing prohibitions. Wider definition of a Politically Exposed Person (e.g. to include the siblings of PEPs in certain cases). More detailed beneficial ownership provisions. The Institute will continue to keep track of AMLA’s work and deliverables over the coming months. This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.

In November 2025, the Financial Conduct Authority (FCA), published findings from a 2025 FCA multi-firm review focusing on business-wide risk assessment and customer risk assessment processes. The FCA fed back its findings on firms identifying, understanding and assessing risk, mitigating risk and managing risk. The findings highlight good and poor practice to help firms reflect on how they are meeting the existing risk assessment requirements. While firms involved in this review are part of FCA regulated population such as building societies, e-money payments firms and wealth management firms, there are general learnings which can be taken from the findings. This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.      

Following its consultation on reforming the UK’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) supervisory regime, the Government has communicated its decision to professional body supervisors (PBSs) to proceed with the creation of a single professional services supervisor. The Financial Conduct Authority will assume responsibility for supervising legal, accountancy and trust and company service providers for AML/CTF purposes. It is therefore the UK Government's intention that the Institute, and other PBSs, will cease to be UK AML supervisors in due course.  It is intended that there will be a transition period, during which the professional bodies will work with HM Treasury and the FCA with regard to the transfer of supervisory responsibilities. The date of transfer of responsibilities has not yet been communicated.   The Institute will consider the full consultation response published by HM Treasury today and, with the other accountancy sector PBSs, will engage with HM Treasury and FCA in relation to the future of the UK AML supervision regime for accountants. In responding to earlier consultations on reform of the AML supervision regime in the UK, the Institute has previously expressed concerns about proposals to move to a single professional services supervisor. The Institute is awaiting more information in relation to this government decision, and we will keep you informed as we receive this.  There is no immediate change for firms currently supervised for AML in the UK by the Institute.  The Institute will support firms through changes arising in relation to the UK AML supervision regime. Further information can be found here.

The AASG have set out guidance on the steps that auditors, insolvency practitioners, external accountants and tax advisers should take when verifying beneficial owners to ensure consistency in approach across the entire sector.

The AASG Risk Outlook has been updated to reflect the UK's National Risk Assessment 2025. The Risk Outlook sets out the key AML risks and red-flag indicators relevant to the accountancy sector. The UK's National Risk Assessment was last updated in July 2025. It is recommended that firms consider the two documents and update their internal AML policies and procedures accordingly.

The Office for Professional Body Anti-Money Laundering Supervision (OPBAS) in the UK supervises the 25 professional body supervisors in the legal and accountancy sectors including Chartered Accountants Ireland. OPBAS has done work in 2025 on assessing the quality of suspicious activity reports (SARs). In order to improve the quality of SARs it is actively working with the UKFIU to support training sessions on SAR quality. UKFIU has recently released a series of videos to support SAR submissions. We encourage our members and firms to view these six SARs Best Practice Videos, available on YouTube and accessible by clicking the links below 1. What is a SAR and why do I need to submit one? 2. Know your Glossary Codes 3. Reason for Suspicion 4. Best practice for completing the criminal / terrorist property section 5. Best practice for completing the prohibited act section 6. What happens after you submit a DAML or DATF? This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.