Anti-money-laundering supervision for bookkeepers: who supervises you and how to check your clients

acrenvo.com/guides/anti-money-laundering-supervision-for-bookkeepers, last reviewed 31 October 2026

Bookkeepers, accountants and tax advisers who work for clients count as accountancy service providers under the money laundering regulations, so they must be supervised and must check who their clients are. For most practices the supervisor is either HMRC or a professional body.

Grace is fictional. After years in a practice, Grace has set up alone, offering bookkeeping and help with Self Assessment to people Grace already knows. Grace has heard that anyone doing this kind of work needs to be “supervised for money laundering”. In practice, Grace wants to know who does the supervising, what to check about each client and what to keep. This guide answers those questions from GOV.UK’s own guidance.

Why bookkeepers are covered

The money laundering regulations name the kinds of business they reach, and accountancy work is one of them. Under money laundering regulations, accountancy service providers are:

• auditors who carry out statutory audit work
• accountants who provide accountancy services to clients
• tax advisers and consultants who provide advice to clients about their tax affairs
• payroll agents that provide accountancy services or tax advice
• customs practitioners, freight forwarders and similar businesses if they provide accountancy or tax services

The services they provide can be recording, reviewing, analysing, calculating and reporting on financial information for other people. This includes:

• professional bookkeeping services
• accounts preparation and signing
• giving a customer specific tax advice
• help with completing and submitting tax returns or duty claims
• advice on whether something is liable to a tax or duty
• advice on the amount of tax or duty that is due

Professional bookkeeping is the first item, so Grace is covered from the first client, and working online does not change that. If you provide these services virtually or through an automated service, you’ll still need to perform customer due diligence on your customer.

Who supervises you

Every business in scope needs a supervisor, and for most practices the choice is between HMRC and a professional body. If you’re an accountancy service provider, you must register with HMRC unless:

• you’re already supervised for money laundering regulations purposes by a professional body
• all your customers are themselves supervised by HMRC or a professional body

For money laundering regulations, the main supervisory bodies for accountants, bookkeepers, tax advisers and other financial advisers are the:

• Association of Accounting Technicians
• Association of Chartered Certified Accountants
• Association of International Accountants
• Association of Taxation Technicians
• Chartered Institute of Management Accountants
• Chartered Institute of Taxation
• Financial Conduct Authority
• Institute of Certified Bookkeepers
• Institute of Chartered Accountants in Ireland
• Institute of Chartered Accountants in Scotland
• Institute of Chartered Accountants of England and Wales
• Institute of Financial Accountants
• Institute of Accountants and Bookkeepers
• Law Society

If you’re supervised by one of these bodies, you do not need to register with HMRC. If Grace belongs to none of them, or belongs to one that does not supervise Grace’s work, HMRC is the supervisor and Grace registers with it.

Supervision is now linked to registering as a tax adviser too. HMRC says:

You need to have approved anti-money laundering supervision in place before you apply for an agent services account. If you’ve already applied without being approved, we will reject your application.

The guide to registering as a tax adviser covers that side.

Checking who your client is

Once supervised, a practice has to check its clients. Customer due diligence means taking steps to identify your customers and checking they are who they say they are. In practice this means obtaining a customer’s:

• name
• photograph on an official document which confirms their identity
• residential address and date of birth

You must apply customer due diligence measures:

• when you establish a business relationship with a customer
• when you suspect money laundering or terrorist financing
• when you have doubts about a customer’s identification information
• when it’s necessary for existing customers — for example, if their circumstances change

The check goes beyond identity. When you establish a new business relationship you need to obtain information on:

• the purpose of the relationship
• the intended nature of the relationship

Where the client is a company or someone acting for another person, the check reaches the person behind them. The beneficial owner is usually the person who’s behind the customer and who owns or controls the customer, or it’s the person on whose behalf a transaction or activity is carried out.

Some clients need more. In some situations you must carry out ‘enhanced due diligence’. One of the situations GOV.UK lists is when the customer is not physically present when you carry out identification checks, which matters for a practice that takes on clients without meeting them. If something does not add up, GOV.UK is direct about it. If you have doubts about a customer’s identity, you must stop dealing with them until you’re sure.

Checking identity online

Many practices now check identity digitally, and GOV.UK has set out when that counts. In order to be used for these checks, digital verification services must be on the GOV.UK Register of services certified against the UK digital verification services trust framework. The new guidance supplements but does not supersede obligations under the MLRs.

That register is public. Anyone can access the register to:

• view the full list of registered digital verification services
• search for a specific digital verification service or provider
• check if a provider holds a valid certificate for its services

It does not help with cost. You cannot use this register to find: commercial information about a provider, such as pricing for services. You can reach the register from GOV.UK’s page on finding registered digital verification services. Acrenvo does not check identity for anyone and names no service.

Controls and records

A one-person practice still needs simple written controls. Your controls should include:

• appointing a ‘nominated officer’ and making sure that employees know to report any suspicious activity to them
• appointing a compliance officer if your business is larger or more complex
• identifying the responsibilities of senior managers and providing them with regular information on money laundering risks
• training relevant employees on their anti-money laundering responsibilities
• documenting and updating your anti-money laundering policies, controls and procedures
• introducing measures to make sure that the risk of money laundering is taken into account in the day-to-day running of your business

You need to keep a record of all customer due diligence measures that you carry out, including:

• customer identification documents that you’ve obtained
• risk assessments
• your policies, controls and procedures
• training records

For the detail behind all of this, HMRC’s manual section for accountancy service providers explains where the sector guidance comes from. HMRC is one of a number of supervisors for accountancy service providers (ASPs). Guidance on The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 for ASPs is published by CCAB on behalf of the accountancy professional bodies and agreed with HMRC and HM Treasury.

HMRC also publishes its own risk assessment of accountancy service providers, which matters for your own. All accountancy service providers (ASPs) must carry out a risk assessment in line with regulations 18 and 18A of the Money Laundering Regulations to identify and assess the risks to their business for:

• money laundering
• terrorist financing
• proliferation financing

You must take this HMRC risk assessment into account when carrying out your business’s own risk assessment.

Checking another business

Sometimes you need to know whether another business is supervised. A full list of HMRC registered businesses is available in the Supervised Business Register. It covers only HMRC’s own supervision, as GOV.UK explains:

Only businesses registered for supervision by us will appear.

Confirmation that a business is registered with us is not an endorsement for you to enter into any commercial transactions with the business.

A business supervised by a professional body will not appear there, so GOV.UK’s page on the Supervised Business Register is only the place to start.

Questions about anti-money-laundering supervision