AML news

From the Professional Accountancy team…... Members may be interested in some opportunities for engagement with the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA). The first is  two public hearings that AMLA  will hold on Tuesday, 24 March 2026. The sessions will focus on two of the regulatory technical standards (RTSs), which are currently open to public consultation and which AMLA is drafting as part of its mandate to implement the Single European Rulebook for AML under the 6th AML Directive (AMLD 6), the Anti-Money Laundering Regulation (AMLR), and the Regulation establishing the AMLA.   The hearing regarding the draft RTS on Customer Due Diligence will be held on Tuesday, 24 March 2026 | 12:30–14:30 (Dublin ). Click for further details and registration. The other session regarding the draft RTS on Criteria for Identifying Business Relationships, Occasional and Linked Transactions and lower thresholds will be held earlier on Tuesday, 24 March 2026 | 09:00–11:00 (Dublin). Click for further details and registration. Click to read more about the Consultation on the draft RTS on Customer Due Diligence Click to read more about the Consultation on the Draft RTS on Criteria for Identifying Business Relationships, Occasional and Linked Transactions and lower thresholds The consultations will close on 8 May 2026. The content of the draft RTSs will be part of the AML regulatory regime upon the coming into force of the majority of the Single European Rulebook in July 2027. Members are encouraged to take the opportunity to familiarise themselves with the content of the draft RTSs and to engage with the hearings and consultations. The Institute will engage in some further outreach to seek members’ views before the conclusion of the public consultations in May. 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.  

Introduction The Economic Crime and Corporate Transparency Act  (ECCTA) which was passed in 2023 continues to bring legal change in the UK. ECCTA introduced identity verification requirements so that UK Companies House will know the identity of anyone setting up, running ,owning or controlling a company in the UK. As part of those changes, ECCTA also introduced the ACSP regime into UK law . A few  strands of the regime, including registration as an ACSP and performing verification and filing are considered in this article. We also consider some challenges which have arisen for our member firms in cases where they are not eligible to register as an ACSP, and we explore further if there are any solutions member firms can adopt. ACSPs :Verification and filing Since 18th November 2025 company directors and people with significant control (PSCs) are legally required to verify their identity under ECCTA. A 12-month transition period is now in place for existing directors and PSCs to comply with the new identity verification requirements by November 2026. The date during the transition period by which directors/PSCs must verify will depend on various factors. This includes whether they are a new director, in which case  they must comply before their registration or appointment as a new director. Existing directors or PSCs must comply based on the company confirmation statement due date during the transition period (and compliance by November 2026 is required). Failure to comply with identity verification requirements on time is an offence. Directors and PSCs can (1) verify themselves directly with Companies House or (2) verify by using an ACSP. Firms which are eligible to register with Companies House as an ACSP (see further below) have been able to register as ACSPs since 18 March 2025. If an accountancy firm  wants to verify its client company directors or PSCs then it must be registered now as an ACSP . Currently there is no change to filing procedures for Companies House and firms can continue to file documents with Companies House in the usual way for their clients without being registered as an ACSP. This will change later in 2026 . In January 2026, Companies House indicated that from no earlier than November 2026, firms will need to be registered as an ACSP to be able to file on behalf of clients. What firms can register with Companies House as an ACSP To become an ACSP, a firm must be supervised within the UK under the UK's Money Laundering Regulations 2017 (the Regulations) by a relevant Anti-Money Laundering (AML) supervisory body. See further details in the following paragraph. What if you cannot register with Companies House as an ACSP The roll out of identity verification and the ACSP regime has given rise to an issue for some Chartered Accountants Ireland member firms which are not AML supervised in the UK . Schedule 1 of the Regulations lists Chartered Accountants Ireland as an AML supervisory authority in the UK in relation to certain "relevant persons", namely relevant persons who are members of the Institute or who are regulated or supervised by it (Regulation 7). The Regulations apply to relevant persons acting in the course of business carried on by them in the United Kingdom. For the purposes of the Regulations a relevant person is to be regarded as carrying on business in the UK where their registered office is in the UK and the day-to-day management of the carrying on of the business is the responsibility of that office, or another establishment in the UK (Regulation 9). Republic of Ireland registered firms may have clients for whom they need to file with Companies House, but if the member firm is supervised for AML purposes in Ireland, not the UK under the Regulations then it is not eligible to register as an ACSP under the legislation as it stands.  In July 2025, the Institute made a representation to the UK Secretary of State for Business and Trade about this issue and for a change in the law to allow Irish AML supervised firms to apply to register as ACSPs. The issue has not yet been resolved to date , and the Institute continues to advocate for this change. If a member firm cannot register because it is not UK AML supervised (firms can check their status with the Institute ) then it might consider putting an arrangement in place with a third party registered  ACSP to carry out verification or filing work on behalf of its clients. If this option is used by member firms, it is considered outsourcing and appropriate outsourcing controls should be implemented by member firms including (1) performance of due diligence regarding the third party registered ACSP prior to appointment, (2) establishment of an outsourcing agreement with the third party ACSP including arrangements regarding information sharing requirements (3) post appointment, the member firm should perform on-going oversight of verification and/or filing activities performed by the third party ACSP on its behalf. The Institute does not endorse or recommend third party ACSPs and we urge members who are considering this route to give careful consideration to the guidance issued by Companies House on the list of ACSPs which it maintains . Members should study the article in full. Please note some of the highlights: the list is not a complete list of all registered ACSPs , it is not updated on a set schedule by Companies House so it may be incomplete or out of date. In addition , before a member  uses a third party ACSP they should always check that the ACSP is not on the list of ceased or suspended ACSPs. The work involved in verification to Companies House by an ACSP  An eligible firm may be considering expanding its offering by registering as an ACSP and taking on new business of verifying directors/PSCs for companies . Before undertaking this work, firms should satisfy themselves as to what is involved. For an ACSP to verify a client , Companies House requires ACSPs to have completed identity checks that meet the Companies House identity verification standard. It is important to note that these are different to customer due diligence checks to prevent money laundering. You can click to read guidance on how to meet Companies House identity verification standard. This includes asking for information about the person, getting  evidence to verify the person’s identity and the documents which can be used as evidence. It also covers the checking of identity documents either electronically by identification document validation technology (IDVT) or checking by a person . If this checking is by a person they must be trained in detecting false documents and be familiar with the guidance on examining identity documents to detect basic forgeries. The requirements to verify documents ,laid out in the guidance, is a significant step up from what is acceptable under anti money laundering  legislation. These checks and verifications will take time and may involve investment in technology or upskilling of people. All of this has  cost implications and will impact those practices which decide to register as ACSPs. Such firms must enhance their procedures and training and plan for this uplift in good time. Acting as an ACSP and performing verification and identity checking may be viable for a firm’s existing clients where the firm already knows much about the client . However , firms must give some pause for consideration of whether there is merit and the cost effectiveness of registering as an  ACSP to take on new business versus the risks which could potentially exist with this new business . Accountancy  firms  should perform their own risk assessment when deciding if they will take on this new business and firms should also ensure that the service is covered under their PII policy. Reminder to member firms to register as an ACSP If an eligible firm is willing to undertake the work involved in being an ACSP and is planning to verify the identity of its client directors and PSCs or wishes going forward to file information at Companies House on behalf of clients (or both) , it must  register to be an ACSP. Eligible firms are encouraged to register now and you can click to read more about how to register as a Companies House authorised corporate service provider and  Applying to register as a Companies House authorised agent - GOV.UK Firms are reminded that - To register you must be supervised for AML in the UK, - When completing the application process, you will be asked to provide your firm identity number, that will be your Institute firm number. Please ensure that the firm’s business name, address and any trading names provided to Companies House match what is recorded with the Institute, otherwise your application may be delayed, -A member’s name and membership number should not be used as the Institute’s authorisation for AML supervision is granted to firms not individuals , -if a sole practitioner is applying for authorisation, please use the unincorporated firm option, - You will be asked to complete identity verification as part of the application process, - There will be a registration fee of £55, payable to Companies House, - Once you are registered, you will be provided with a new digital account and unique identity number. This will allow you to file information and complete identity verification for your clients. 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.  

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.