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AASG Risk Outlook: Anti-Money Laundering Guidance Update

Last updated: 26 Sep 2025 09:00 Posted in: Anti-money laundering

The Accountancy AML Supervisors’ Group (AASG) has published its latest ‘Risk Outlook – High Risk Circumstances’, dated 22 September 2025, outlining the evolving landscape of money laundering, terrorist financing, and proliferation financing risks in the UK accountancy sector.

AASG is comprised of the thirteen accountancy professional body supervisors (PBSs) who are supervisory authorities under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR17). These bodies work together to develop consistent policies and best practices for anti-money laundering and counter-terrorist financing supervision in the accountancy sector.

The impact of money laundering is devastating – it enables serious organised crime such as modern slavery, drugs trafficking, fraud, corruption and terrorism.

A comprehensive risk assessment is key to understanding the money laundering (ML), terrorist financing (TF) and proliferation financing (PF) risks that a business is exposed to.

By knowing and understanding the risks to which the accountancy sector is exposed, HM Government, law enforcement, and the professional body supervisors, as well as the accountancy firms themselves, can work together to ensure that criminals find it difficult to exploit accountancy services.

This updated guidance is essential reading for all AIA members, particularly those working in external accounting, tax advisory, and trust or company services. It highlights:

  • Emerging threats such as cryptoasset misuse, AI-driven fraud, and sanctions evasion.
  • High-risk services including payroll, tax advice, company formation, and accountants’ certificates of confirmation.
  • Red flag indicators for client behaviour, including secrecy, complex ownership structures, and links to high-risk jurisdictions.
  • Sector-specific vulnerabilities, including cash-based businesses.
  • New obligations around identity verification for Companies House.

The document also reinforces the importance of professional scepticism, robust AML policies, and tailored risk assessments. Firms are reminded to regularly review their exposure and update procedures accordingly.

David Potts, AIA Director of Policy & Regulation and MLRO said, “This updated AASG Risk Outlook is a vital resource for AIA members. It reflects the increasingly complex threats facing the accountancy sector, from cryptoassets and AI-driven fraud to sanctions evasion. All firms should review the guidance and ensure their AML policies and risk assessments are updated.”

AIA members are strongly encouraged to read the full AASG Risk Outlook and integrate its findings into their firm-wide risk assessments and AML controls. The document complements the UK’s National Risk Assessment (NRA) and should be used alongside it.

Additional supplementary guidance has also been released relating to verifying the beneficial owners of clients.

Further guidance is available for AIA members by logging in and accessing the AML hub.

“This updated AASG Risk Outlook is a vital resource for AIA members. It reflects the increasingly complex threats facing the accountancy sector, from cryptoassets and AI-driven fraud to sanctions evasion. All firms should review the guidance and ensure their AML policies and risk assessments are updated.”

David Potts, Director of Policy & Regulation, AIA