AML Policies, Controls and Procedures Manual

A complete written AML manual for an accountancy or bookkeeping practice: governance, MLRO, due diligence, reliance, monitoring, reporting, tipping off, training, screening, records and independent audit.

Editable Word document
17
10pages
Guidance notes included
aml consultancy solutions

Accountancy practice – compliance & management

AML Policies, Controls and Procedures Manual

About this document

What it’s for

The written policies, controls and procedures required by regulation 19 of the Money Laundering Regulations 2017 as amended (“MLRs”), tailored to accountancy and bookkeeping practices. It tells everyone in the firm what they must do – from client take-on to reporting suspicions – and gives your supervisor evidence that your controls are proportionate, approved by senior management and actually followed.

When to use it

  • As the firm’s core AML compliance document, approved by senior management
  • For induction and annual training of every partner, employee and subcontractor
  • When your supervisor asks to see your policies, controls and procedures

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  1. Purpose and policy statement
  2. Scope
  3. Legal and regulatory framework
  4. Definitions
  5. Governance, roles and responsibilities
  6. Risk assessment
  7. Customer due diligence
  8. Simplified due diligence
  9. Enhanced due diligence
  10. Politically exposed persons
  11. Sanctions screening
  12. Where CDD cannot be completed
  13. Reliance and outsourcing
  14. Ongoing monitoring
  15. Recognising suspicious activity
  16. Internal reporting
  17. MLRO evaluation and reporting to the NCA
  18. Tipping off and prejudicing an investigation
  19. Client money, fees and payments
  20. Record keeping
  21. Training and awareness
  22. Screening of relevant employees
  23. Independent audit function
  24. Compliance monitoring and management information
  25. Dealing with the supervisor
  26. Data protection
  27. Breaches of this manual
  28. Review

Also included

  • Client identity and behaviour
  • Records and business activity
  • Tax
  • Fees and payments
  • Geography and sanctions
  • Appendix B – Key contacts
  • Appendix C – Staff acknowledgement

How to complete it

  • Insert names, thresholds and timescales and choose between the options given
  • Delete anything that does not apply (for example the trust or company service provider sections if you offer none)
  • Make sure it matches your firm-wide risk assessment, client risk assessment form and the CDD checklist you use
  • Have it approved, issued to staff with the acknowledgement in Appendix C, and reviewed at least annually

Key points to check

  • Updated for SI 2026/621 (in force 30 June 2026) and the CCAB 2026 sector guidance
  • Use with the separate Anti-Money Laundering Client Identification Checklist for the detailed CDD record

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

Included in the pack

Accountancy practice – compliance & management

£20

for every document in this category

Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

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