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AML Consultancy for Accountants & Accountancy Firms


Practical anti-money laundering consultancy for accountants and accountancy practices. From Firm-Wide Risk Assessments to independent compliance reviews, we help firms strengthen their AML framework and remain ready for supervisory scrutiny.

Fixed-price consultancy wherever possible

Independent AML compliance specialists

Delivered across the UK, in-person or remotely

AML Compliance Is an Ongoing Obligation. We Help You Remain Inspection Ready.


The Money Laundering Regulations 2017 place ongoing anti-money laundering obligations on regulated accountancy practices, regardless of their size. It's no longer enough just to have policies and procedures in place; firms must be able to demonstrate that their AML framework is proportionate, up to date, and effectively embedded across the practice.

Whether you're preparing for a monitoring visit or strengthening your firm's compliance framework, PDA Legal provides practical AML consultancy tailored to accountancy firms' needs. We help you identify gaps, implement proportionate improvements, and build robust compliance arrangements that support both your regulatory obligations and your day-to-day operations.

Who We Support


Whether you're a sole practitioner or a larger multi-office firm, our AML consultancy is tailored to the way your business operates.

We understand that in many smaller practices, the partner is often also the MLRO and MLCO, balancing compliance responsibilities alongside day-to-day client work. This is why our advice is actionable, proportionate, and designed to reduce the burden wherever possible.

We also support firms supervised directly by HMRC, helping them build robust AML frameworks that meet their obligations with confidence. Whatever your firm's size or supervisory arrangements, we provide consultancy tailored to your risk profile rather than a one-size-fits-all solution.

Where Firms Usually Encounter Issues


More often, compliance gaps appear gradually as regulations evolve, services expand, responsibilities change, or documentation simply fails to keep pace with how the practice actually operates.

For many firms, these issues only come to light when preparing for a supervisory monitoring visit or responding to findings from a previous review. Common examples include:

  • Policies and procedures downloaded from a template but never adapted to reflect the firm's actual services and risks
  • Documentation that no longer matches how the firm operates day-to-day
  • Inconsistent client onboarding and Customer Due Diligence (CDD) processes between members of staff
  • Unclear responsibilities where a partner or senior team member has taken on the role of MLRO or MLCO without sufficient support
  • Limited evidence showing that AML processes are being followed in practice

Other challenges can arise when firms encounter higher-risk situations, such as unexplained capital introductions, requests to amend historic accounts, or client activity that does not align with their known circumstances.

Our consultancy helps identify these gaps and strengthen existing arrangements so that your AML framework accurately reflects the way your practice operates.

AML Policies, Controls & Procedures Support

Under Regulation 19 of the Money Laundering Regulations 2017, regulated accountancy firms must establish and maintain written AML policies, controls, and procedures that are proportionate to the size and nature of their business.

The challenge isn't simply having documentation in place - it's ensuring those policies genuinely reflect how your firm operates. During a monitoring visit, supervisors will expect your procedures and day-to-day practices to align.

We Can Review
  • AML Policy
  • Customer Due Diligence (CDD)
  • Enhanced Due Diligence (EDD)
  • Ongoing Monitoring
  • Internal Reporting & Suspicious Activity Report Procedures
  • Record Keeping

Why Generic Templates Can Create Risk

A generic AML manual can be worse than useless. It can create a false sense of confidence while committing your practice to controls that are not actually being followed.

If your documentation says one thing but your team does another, this inconsistency is likely to become apparent during a supervisory review. Effective AML procedures should not simply exist on paper - they should reflect your firm's actual working practices.

Example Scenario

A client asks for accounts to be backdated after year-end.

Your AML procedures should help your team understand:

  • Whether this creates additional risk concerns
  • Whether further Customer Due Diligence is required
  • Whether the matter should be escalated internally
  • Whether a Suspicious Activity Report should be considered

If your policies don't provide clear guidance, staff are left making judgement calls that may be inconsistent across the practice.

Our consultancy helps ensure your AML policies are unique to your firm's services, giving your team documentation they can confidently follow and evidence during supervisory monitoring visits.

Two business professionals having a discussion at a table, with one gesturing while speaking. An open laptop and a cup of coffee are on the table in a bright office setting.

MLRO & MLCO Support


Taking on the role of MLRO or MLCO brings significant responsibility, yet many people inherit these roles with little formal handover or practical support.

Whether you're newly appointed or balancing compliance alongside client work, PDA Legal provides expert guidance to help you fulfil your responsibilities with confidence.

Newly Appointed MLROs & MLCOs

Receive actionable guidance if you've recently taken on the role, helping you understand your responsibilities, review existing AML arrangements, and identify where improvements may be needed.

Support for Sole Practitioners & Small Firms

In many smaller accountancy practices, one person is responsible for both compliance and fee-earning work. We provide proportionate advice that helps you manage your AML obligations without creating unnecessary administrative burden.

Fit & Proper Requirements

We can advise on the approval and fit and proper requirements that apply to beneficial owners, officers, and managers, helping ensure your firm meets its regulatory obligations.

Looking to strengthen your knowledge in the role? Explore our dedicated AML compliance training tailored to accountancy practices.

Ongoing AML Compliance Support


AML compliance is not a one-off exercise. As regulations evolve, your services develop, and your client base changes, your AML framework needs to keep pace.

Many firms choose to work with PDA Legal as an ongoing compliance partner, providing access to practical advice and support whenever requirements change (or questions arise).

Regulatory & Guidance Updates

We explain what changes to legislation and industry guidance mean for your practice, highlighting any actions you may need to take.

Regular Policy Reviews

We review your AML policies and procedures to ensure they continue to reflect your firm's services, risks, and regulatory responsibilities.

A Named Compliance Contact

Rather than navigating compliance questions alone, you have access to a dedicated point of contact who understands your practice.

Support With Supervisory Reviews

Whether responding to supervisor correspondence or preparing for a monitoring visit, we help you understand expectations and prioritise the right actions.

Growing With Your Practice

As your firm expands or introduces new services, we help ensure your AML arrangements develop alongside your business.

Our AML Consultancy Process


Whether you're looking for a one-off compliance review or ongoing AML support, we follow a structured process designed to identify compliance gaps and prioritise improvements:

1. Initial Consultation (Free & No Obligation)

We begin with an introductory conversation to understand your practice, including the services you provide, your client base, supervisory arrangements, and existing AML framework. This allows us to recommend the most appropriate level of support without obligation.

2. Compliance Review

Our consultants review your existing documentation, policies, and procedures against the MLR 2017 and the CCAB Anti-Money Laundering Guidance for the Accountancy Sector (AMLGAS). We'll identify any gaps or areas that could benefit from improvement before they become issues during a supervisory review.

3. Practical Recommendations

You'll receive clear and prioritised recommendations. We'll explain what must change to meet regulatory requirements, what should be improved, and what is already working well, so you can focus your time and resources where they'll have the greatest impact.

4. Ongoing Compliance Support

AML compliance doesn't stand still, and neither do we. As your practice grows or regulatory expectations change, we're on hand to help you maintain a compliance framework that continues to reflect your business.

Tailored AML Support for Your Practice

Every accountancy firm has different AML requirements, challenges and priorities. Rather than taking a one-size-fits-all approach, we begin by understanding your firm's current position, regulatory obligations and the areas where you need support. From there, we provide proportionate advice and implement the right solutions for your practice.

Developing a Firm-Wide Risk Assessment

Many firms approach PDA Legal because they need support creating or strengthening their Firm-Wide Risk Assessment (FWRA). We work with you to develop a risk assessment that accurately reflects your services and exposure to money laundering risks.

Reviewing Existing AML Controls

If you already have AML documentation in place, we can review your existing controls and provide honest feedback. This may include assessing your AML policies, FWRA, client risk assessment processes, and other compliance documentation to identify areas for improvement.

Preparing for Supervisory Reviews

Whether you have an upcoming monitoring visit, have received findings from a previous review or simply want reassurance that your compliance framework is robust, we can help you understand where improvements are needed and prioritise the actions required.

Whatever your reason for seeking support, our consultancy leaves you with a clear documentary record of the work completed, helping demonstrate your commitment to effective AML compliance during future supervisory enquiries.

Why Choose PDA Legal?

Choosing an AML support partner is about more than finding someone who understands the regulations. You need practical advice from specialists who can understand your firm's challenges and day-to-day operations.

  • Independent AML Specialists, Not a Template Provider: Practical and expert guidance tailored to your firm's specific compliance requirements.
  • Advice Built Around Your Practice: Proportionate recommendations based on your firm's size, services, client base, and risk profile.
  • Fixed Pricing Agreed Upfront: Clear costs before work begins, wherever possible, with no unexpected fees.
  • A Long-Term Compliance Partner: Ongoing support as regulations evolve, your services change, and your practice grows.

Book Your AML Compliance Review Today

AML compliance doesn't need to be overwhelming. Our consultants help accountancy firms build proportionate compliance frameworks that meet regulatory expectations while supporting day-to-day business operations.

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FAQs


What AML regulations apply to accountants?

Accountancy firms carrying out regulated activities must comply with the Money Laundering Regulations 2017, which set out requirements for areas such as risk assessments, AML policies, procedures, and staff training.

Who supervises AML compliance for accountancy firms?

AML supervision depends on the firm's professional body membership and registration status. Firms may be supervised by bodies such as ICAEW, ACCA, ICAS, CIMA, CIOT, and others, while firms outside professional body supervision may be regulated directly by HMRC.

What is a Firm-Wide Risk Assessment (Regulation 18)?

A Firm-Wide Risk Assessment is a documented assessment of the money laundering and terrorist financing risks specific to your practice. Under Regulation 18 of the MLR 2017, firms must identify and assess the risks associated with factors such as their clients, services, delivery channels, and geographic exposure.

PDA Legal can help create, review, or update your FWRA so it accurately reflects how your firm operates.

Does every accountancy firm need an independent audit function?

Not necessarily. Under Regulation 21 of the MLR 2017, the requirement for an independent audit function is proportionate to the size and nature of the business.

Larger or higher-risk firms may need a more formal review process, while smaller practices may require different arrangements. Our experts can help you understand what is appropriate for your firm's circumstances.

Is your consultancy aligned with AMLGAS guidance?

Yes, PDA Legal's approach is informed by the CCAB Anti-Money Laundering Guidance for the Accountancy Sector (AMLGAS), helping accountancy firms implement practical AML arrangements that reflect current regulatory expectations and industry best practice.

Can you review our existing AML documentation?

Yes, PDA Legal can review existing AML documentation, including policies, FWRAs, and client risk assessment processes. We identify any gaps or areas for improvement, providing practical recommendations that help ensure your documentation reflects how your firm operates in practice.

Can you help prepare for an ICAEW, ACCA or HMRC monitoring visit?

Yes, PDA Legal can support firms preparing for supervisory monitoring visits by reviewing existing AML arrangements, identifying potential areas of concern, and helping prioritise any required improvements. We can also provide guidance when responding to findings or recommendations following a review.

Do you support firms providing Trust or Company Service Provider services?

Yes, PDA Legal supports accountancy firms carrying out higher-risk activities such as company formation, registered office services, and other Trust or Company Service Provider (TCSP) activities. We can help ensure your AML framework, risk assessments, and procedures appropriately reflect these additional responsibilities.

How quickly can an AML compliance review be completed?

Timescales depend on the scope of work required, the size of your firm, and the complexity of your existing AML arrangements.

During an initial consultation, we will discuss your requirements and provide a clear outline of the expected timeframe and next steps.