We operate with complete integrity, keeping our clients fully informed at every step. Your business goals become our mission, and we approach every challenge with openness, clarity, and unwavering honesty.
We take full responsibility for our actions, decisions, and advice. Our clients can rely on us to deliver on our promises, proactively address challenges, and ensure every outcome aligns with your business goals.
We go beyond the ordinary, combining forward-thinking strategies with cutting-edge digital solutions tailored to your business. By anticipating challenges and embracing new opportunities, we create smarter, more effective ways to help your business thrive.
We build true partnerships with our clients, working hand-in-hand to deliver outstanding results. By blending our expertise with your ambitions, we create seamless collaboration that drives success and exceeds expectations.
AML Accountancy Solutions is fully committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in all aspects of its operations. As a firm regulated by the Association of Chartered Certified Accountants (ACCA), we are subject to strict professional and legal obligations in relation to the prevention of money laundering and terrorist financing.
Money laundering is the process by which criminal proceeds are disguised to make them appear legitimate. Terrorist financing involves the raising, movement, or use of funds intended to support terrorist activity. Both are serious criminal offences under UK law.
This policy establishes the framework through which AML Accountancy Solutions identifies, assesses, mitigates, and reports AML risks. It is designed to ensure full compliance with the UK Money Laundering Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000, HM Treasury guidance, and ACCA ethical and professional standards.
The policy exists to protect the firm, its clients, employees, and the wider financial system from exploitation by criminals. It also ensures that the firm operates with a consistent, risk-based approach to compliance across all services and engagements.
This policy applies to all individuals associated with AML Accountancy Solutions, including directors, employees, contractors, consultants, temporary staff, and any third parties acting on behalf of the firm.
It applies to all services offered by the firm, including accountancy, bookkeeping, payroll, VAT services, taxation, financial reporting, business advisory services, and any related compliance or consultancy services.
It also applies to all clients, whether individuals, sole traders, partnerships, limited companies, charities, trusts, or complex corporate structures, regardless of size, location, or risk profile.
Compliance with this policy is mandatory and forms an ongoing condition of engagement with the firm.
The firm operates within a comprehensive UK AML and financial crime prevention framework, including:
the UK Money Laundering Regulations 2017, which govern customer due diligence, risk assessment, record keeping, and ongoing monitoring obligations;
the Proceeds of Crime Act 2002, which defines money laundering offences and reporting duties; the Terrorism Act 2000, which requires reporting of suspected terrorist financing activity;
HM Treasury and supervisory authority guidance for professional body supervisors; and the ACCA Code of Ethics and Professional Conduct, which requires integrity, objectivity, competence, confidentiality, and professional behaviour.
The firm also complies with the Data Protection Act 2018 and UK GDPR in relation to the lawful processing and storage of personal data obtained for AML purposes.
AML responsibility is embedded across the firm and overseen at senior management level.
A designated Money Laundering Reporting Officer (MLRO) is appointed with responsibility for overseeing AML compliance, receiving internal reports, assessing suspicious activity, and making external disclosures to the National Crime Agency where required.
All staff are individually responsible for complying with AML procedures, undertaking due diligence, maintaining awareness of risks, and escalating concerns promptly.
Senior management is responsible for ensuring that adequate resources, systems, and controls are in place to support effective AML compliance.
Compliance is subject to ongoing review, oversight, and internal assurance procedures.
The firm applies a risk-based Client Due Diligence framework to all clients before establishing any business relationship.
Identity verification is required for all clients and relevant connected parties. For individuals, this includes verification of full legal name, date of birth, residential address, and valid photographic identification, supported by independent verification sources where necessary.
For corporate clients, the firm undertakes verification of company registration details, business activity, legal structure, and full beneficial ownership. All individuals owning or controlling 25% or more of the entity, or otherwise exercising control, must be identified and verified.
For trusts, partnerships, and complex arrangements, additional verification is carried out on trustees, partners, beneficiaries, settlors, and any underlying controlling persons.
Enhanced Due Diligence is applied where higher risk is identified. This includes Politically Exposed Persons (PEPs), clients operating in high-risk jurisdictions, complex or opaque ownership structures, unusual transaction patterns, or where the source of funds or wealth cannot be clearly established.
No services will be provided until satisfactory due diligence has been completed.
AML Accountancy Solutions operates a formal, documented, risk-based assessment process for all clients.
Each client is assessed at onboarding and periodically throughout the relationship. Risk scoring considers multiple factors including:
the nature of the client’s business and industry sector;
the geographical locations involved in the client’s operations or transactions; the complexity of ownership structures;
the transparency and reliability of source of funds and source of wealth; the expected volume, frequency, and nature of transactions; and
any known exposure to high-risk activities or jurisdictions. Clients are categorised as low, medium, or high risk.
Low-risk clients typically involve straightforward structures, clear ownership, and predictable transaction patterns. Medium-risk clients may involve moderate complexity or limited uncertainty. High-risk clients involve elevated AML concerns requiring enhanced due diligence, senior approval, and increased monitoring.
Risk ratings are not static and are reviewed regularly or whenever new information becomes available.
Ongoing monitoring is a continuous requirement throughout the client relationship.
The firm reviews client activity to ensure that transactions remain consistent with the firm’s understanding of the client’s business and risk profile.
Monitoring includes reviewing financial activity patterns, identifying deviations from expected behaviour, and assessing whether transactions have a clear economic or commercial rationale. The firm remains alert to potential warning signs, including unusually large or structured transactions, unexplained changes in financial behaviour, use of third parties without clear purpose, rapid movement of funds, or exposure to high-risk jurisdictions.
Where concerns arise, these are escalated to the MLRO for further investigation. Monitoring is dynamic and risk-based, with higher-risk clients subject to more frequent review.
AML Accountancy Solutions maintains comprehensive and secure records to demonstrate compliance with all AML obligations.
Records include client identification documents, verification evidence, risk assessments, ongoing monitoring records, correspondence, engagement documentation, and internal reports relating to suspicious activity.
Records are retained for a minimum of five years after the end of the client relationship or completion of the transaction, in line with legal requirements.
All records are stored securely using controlled access systems, ensuring confidentiality, integrity, and protection against unauthorised access or misuse.
All staff are legally required to report any knowledge, suspicion, or reasonable grounds for suspicion of money laundering or terrorist financing.
Internal reports must be submitted immediately to the MLRO, who is responsible for evaluating the information and determining whether a Suspicious Activity Report (SAR) must be submitted to the National Crime Agency.
Where a SAR is submitted, the firm may be required to obtain consent before proceeding with certain transactions under the Proceeds of Crime Act 2002.
All SAR-related information is strictly confidential. It is a criminal offence to disclose information that could prejudice an investigation or alert a subject to the existence of a report. The firm maintains detailed internal records of all reports, assessments, and outcomes.
AML training is mandatory for all staff and forms a core part of the firm’s compliance framework.
All new employees receive AML training as part of their induction process. This training covers UK AML legislation, the Proceeds of Crime Act, terrorist financing risks, customer due diligence procedures, identification of suspicious activity, internal reporting processes, and the role of the MLRO.
In addition to induction training, all staff receive refresher training at least annually. Additional training is provided when there are changes in legislation, regulatory guidance, or internal procedures.
Training also includes case studies, real-world typologies, and scenario-based learning to ensure staff are able to identify and respond appropriately to potential risks.
Attendance and completion of training are recorded and monitored as part of the firm’s compliance oversight.
The firm maintains a structured internal control environment designed to ensure effective AML compliance.
This includes documented onboarding procedures, verification protocols, risk assessment frameworks, escalation processes, and reporting mechanisms.
The firm applies segregation of duties where appropriate to reduce the risk of fraud, error, or misuse.
Internal compliance reviews are conducted periodically to assess the effectiveness of AML controls and identify areas for improvement.
The MLRO reports regularly to senior management on AML matters, including risk exposure, incidents, and compliance performance.
AML Accountancy Solutions maintains a full and unconditional commitment to cooperating with all relevant regulatory, supervisory, and law enforcement authorities in the United Kingdom and, where applicable, international counterparts.
We recognise that effective anti-money laundering enforcement relies on timely, accurate, and transparent cooperation between regulated firms and public authorities. As such, we will comply fully with all lawful requests for information, documentation, and assistance issued by bodies including HM Revenue & Customs, the National Crime Agency, Companies House, the Financial Conduct Authority (where applicable), and any other competent authority or law enforcement agency.
Where a formal or statutory request for information is received, the firm will respond within the required timeframe and provide all relevant documentation in a secure, accurate, and complete manner. This includes client identification records, due diligence files, transaction histories, correspondence, risk assessments, and internal compliance records where legally permitted.
We will also cooperate fully with investigations relating to suspected money laundering, terrorist financing, tax evasion, fraud, or other financial crime. This includes preserving relevant records, avoiding any action that may prejudice an investigation, and ensuring that confidentiality obligations are upheld in accordance with the Proceeds of Crime Act 2002 and other applicable legislation.
Where required, the firm will also cooperate with professional regulatory bodies, including ACCA, in relation to compliance reviews, monitoring visits, or investigations into professional conduct.
All cooperation with authorities will be handled in a controlled, confidential, and compliant manner, ensuring that legal obligations are met while maintaining the integrity and security of client data.
Clients of AML Accountancy Solutions are required to comply with all legal, regulatory, and contractual obligations necessary to support the firm’s anti-money laundering compliance framework.
Clients must provide accurate, complete, and up-to-date information at all times, including but not limited to identity documentation, business records, ownership structures, financial information, and any other material required for customer due diligence purposes. This obligation extends to all beneficial owners, directors, trustees, partners, and any other relevant connected persons.
Clients are responsible for ensuring that any information provided is truthful and not misleading. The provision of false, incomplete, or deliberately misleading information may result in immediate suspension or termination of services and may be reported to the relevant authorities where required by law.
Clients must notify the firm promptly of any changes to their circumstances that may affect their AML risk profile. This includes changes in ownership, control, business activities, jurisdictional exposure, or financial behaviour.
Clients must cooperate fully with all reasonable requests for additional documentation or clarification made by the firm for the purposes of complying with AML obligations. Failure to
provide requested information within a reasonable timeframe may result in delays, restriction of services, or termination of the business relationship.
Clients must not use the services of AML Accountancy Solutions for any unlawful purpose, including but not limited to money laundering, terrorist financing, tax evasion, fraud, or any activity that may breach UK law or professional standards.
Clients also acknowledge that the firm is legally required to conduct due diligence and ongoing monitoring and that services cannot be provided where such requirements cannot be satisfied.
AML Accountancy Solutions reserves the absolute right to refuse onboarding, suspend services, or terminate any client relationship immediately where necessary.
This includes situations where:
due diligence cannot be completed satisfactorily required documentation is not provided
identity or ownership cannot be verified source of funds or wealth is unclear AML risk is deemed unacceptable
legal or regulatory obligations require disengagement
This applies to direct clients and any indirect representatives, agents, or intermediaries.
We also reserve the right to disengage where documentation is withheld, delayed, refused, or not reasonably provided.
We are under no obligation to continue providing services where AML compliance requirements cannot be met.
This Anti-Money Laundering Policy is subject to regular review to ensure that it remains current, effective, and fully aligned with all applicable legal, regulatory, and professional requirements.
At a minimum, this policy is reviewed annually by senior management and the Money Laundering Reporting Officer. However, reviews may also be conducted more frequently where there are significant changes in legislation, regulatory guidance issued by supervisory authorities, updates to ACCA requirements, or changes in the firm’s risk profile, client base, or service offerings.
The review process considers the effectiveness of existing controls, the adequacy of internal procedures, emerging risks within the financial crime environment, and any incidents or near misses identified during the review period.
Where improvements are identified, the firm will update policies, procedures, and training materials accordingly to ensure continuous strengthening of the AML control environment.
All updates to this policy are formally approved by senior management prior to implementation. Relevant staff are notified of any changes, and additional training is provided where necessary to ensure full understanding and compliance.
The firm is committed to a process of continuous improvement in relation to AML compliance, ensuring that systems, controls, and procedures evolve in line with best practice, regulatory expectations, and emerging financial crime threats.
This policy is reviewed at least annually or more frequently where required due to regulatory changes, risk developments, or operational updates.
Updates are approved by senior management and communicated to all relevant personnel. Training and procedures are updated accordingly.
Money Laundering Reporting Officer (MLRO): Adam Sloan Email: info@amlaccountancysolutions.co.uk
Telephone: 01752 42 72 82
Address: First Floor Unit D2, 4 Neptune Park, Plymouth, PL4 0SJ
AML Accountancy Solutions is fully committed to preventing financial crime and maintaining the integrity of the UK financial system.
We operate a zero-tolerance approach to non-compliance with AML obligations and maintain robust systems, controls, and procedures to ensure full regulatory compliance.
By engaging with AML Accountancy Solutions, clients and associated parties acknowledge and agree to comply with this policy in full, including our right to refuse, suspend, or terminate services where AML requirements are not met.