Two things changed this summer for accountancy practices supervised by HMRC for anti-money laundering. Amendments to the Money Laundering Regulations came into force on 30 June 2026, and on 8 July 2026 HMRC published a new consolidated anti-money laundering manual that includes a detailed risk assessment for accountancy service providers. The practical upshot is that you should revisit your firm-wide risk assessment, your client risk factors and your identity checks now, rather than at your next annual review.
What has changed in the law
The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621) amend the Money Laundering Regulations 2017. HMRC’s new manual confirms that the amendments came into force on 30 June 2026. According to the explanatory note, the changes include:
- Euro amounts in the regulations replaced with sterling equivalents on a one-for-one basis, so thresholds no longer need converting.
- The term “high-risk third country” replaced with “FATF call for action country” in the enhanced due diligence rules.
- Extra due diligence requirements for providers of pooled accounts.
- Changes for trust or company service providers, including bringing the sale of off-the-shelf companies into scope as a business relationship.
- Changes to trust registration and to information sharing between supervisors and others, including the registrar of companies.
Not every change will affect a typical accountancy practice. The enhanced due diligence wording, the sterling thresholds and, if you form or sell companies, the trust or company service provider changes are the ones most practices should check against their policies.
HMRC’s new anti-money laundering manual
On 8 July 2026 HMRC published Anti-money laundering guidance for supervised businesses, a single manual covering all nine sectors HMRC supervises. It has three parts: guidance for all sectors, sector-specific guidance, and sector risk assessments.
For accountancy service providers, the manual is clear that there is separate guidance from the Consultative Committee of Accountancy Bodies (CCAB). If you provide accountancy services, follow the CCAB guidance for that work. If you also provide trust or company services, such as company formation or a registered office address, follow HMRC’s manual for that part of your business.
The section that matters most for every accountancy practice is the new sector risk assessment for accountancy service providers at AMLG3700. Your own risk assessment must take HMRC’s assessment into account.
The risks HMRC has set out for accountancy practices
HMRC lists risks that are common to all accountancy service providers, and then risks specific to accounting, bookkeeping, tax advice, payroll and audit work. They include:
- Instructions with no clear business reason or that make little economic sense.
- Links to FATF call for action countries or other higher-risk jurisdictions.
- Clients introduced through intermediaries or supply chains, including intermediaries that are not supervised for anti-money laundering.
- No face-to-face contact, cash-intensive businesses and apparent shell companies.
- Frequent changes of beneficial ownership, or significant unexplained changes in the business.
- Clients who use several accountancy firms without a clear reason, or who are secretive about their finances.
- Preparing accounts or records from incomplete or unverified information.
- Pressure from a client to reduce their tax bill by improper means.
- Payroll risks, including falsified instructions and links to umbrella company fraud.
Modern slavery and human trafficking
A notable addition is the focus on modern slavery and human trafficking. HMRC describes these as financially motivated crimes and identifies labour-intensive, low-margin businesses as more vulnerable to exploitation. For payroll work, it highlights warning signs such as inconsistencies between hours and pay, unusually low National Insurance contributions, round-sum salaries and wage patterns that do not fit the workforce. HMRC points practices to National Crime Agency material on indicators of modern slavery and human trafficking in the accountancy sector.
If you run payroll for clients in sectors where workers may be vulnerable, this deserves a specific entry in your risk assessment and in staff training.
Identity verification expectations
HMRC’s manual section on identifying and verifying customers sets out the basics: for individuals, obtain and verify full name, date of birth and residential address, and if you cannot verify identity, do not proceed. It also recognises digital identity services certified against the UK digital verification services trust framework as a reliable and independent source. For companies, a Companies House check of people with significant control is useful, but it does not on its own satisfy the requirement to verify beneficial owners.
Accountancy practices should read this alongside the CCAB guidance, which remains their primary guidance for accountancy work.
What to do now: a practical checklist
| Area | Action |
|---|---|
| Firm-wide risk assessment | Review it against HMRC’s ASP risk assessment and record the date, sources and outcome. |
| Policies, controls and procedures | Update references to “high-risk third countries” and any euro thresholds. |
| Client risk assessment | Add or sharpen risk factors for intermediaries, cash businesses, incomplete records and modern slavery indicators. |
| Identity checks | Confirm your verification methods, including any digital identity provider, meet current expectations. |
| Trust or company services | If you form companies or provide registered offices, check the new rules and HMRC’s sector guidance. |
| Training | Brief staff, especially payroll teams, on the new risk areas and how to raise concerns internally. |
| Records | Keep previous versions of your risk assessment, as HMRC can ask to see them. |
Frequently asked questions
When did the 2026 changes to the Money Laundering Regulations come into force?
HMRC’s manual confirms the amending regulations, SI 2026/621, came into force on 30 June 2026. A small number of provisions start later, in 2027.
Do accountancy practices follow HMRC’s new manual or the CCAB guidance?
For accountancy work, the CCAB guidance. HMRC’s manual applies to trust or company services, and its accountancy sector risk assessment should inform your own risk assessment.
Do we need to redo our firm-wide risk assessment?
You need to keep it up to date and take HMRC’s risk assessment into account. A documented review now, noting what you changed and why, is a sensible step.
Why is modern slavery now part of anti-money laundering risk?
Because it generates criminal proceeds that can pass through legitimate businesses. HMRC highlights labour-intensive sectors and payroll work as areas where accountants may spot the signs.
How Engager helps
Engager supports AML checks through integrations with Xama and Armalytix, so identity checks can sit alongside the rest of your client onboarding. Client onboarding forms help you collect the information you need at the start, and the Companies House integration brings in company details.
You can use custom fields to record client risk ratings and checklists to make sure each review step is completed and evidenced.
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