Source of risk assessment checklist and money laundering manual | AccountingWEB

Source of risk assessment checklist and money laundering manual


I am a small sole practitioner and have been acting within the spirit of the money laundering regs (i.e. checking ID and informally assessing the risk of ML) but realise that i need to formalise the procedures I use.

Does anyone know of a risk assessment checklist and money laundering manual that I can buy and then adapt to my small practice?


Richard FTAX's picture

AML Risk Assessment

Richard FTAX | | Permalink

Legatio Technologies plan to include an AML Risk Assessment form in their Legatio KYC Anti Money Laundering product. This also includes a draft Policies & Procedures document aimed at accountants.

If anyone would like to be emailed a FREE PDF demonstation version of this AML Risk Assessment form, please email [email protected]. The form has been designed for Accountancy Service Providers and only takes a few minutes to complete.

A copy (of the 'live' version) may be saved to provide a record of the risk assessment. Everyone is legally obliged to keep a record of each AML risk assessment for at least 5 years after the business relationship with the client ends.




SWAT general practice and procedures manual

Anonymous | | Permalink

Have a look at the Swat limited , General practice procedures manual. good and affordable.

No commission for me on this independant advice ! you can owe me a pint ! lol

Sara R's picture

Hope this helps...

Sara R | | Permalink

Hi Luke,

I'm not sure where you can get a manual from in order to find this out. However, as from the 15th January there will be new AML regulations. This will state that you can no longer just take photocopies to comply with aml. Why spend money on manuals to tell you how to do this when you can put the money towards getting a system that can allow you do comply with the new law.


value for money

Anonymous | | Permalink

Because the manual is value for money. This electronic check is just an excuse to rip us off.

Sara R's picture

Electronic Checks

Sara R | | Permalink

I am not trying to rip anyone off... I thought forums were there to help people in business

I was told about the new regulations through a customer so thought would let everyone know this before you get people calling you trying to sell you the reports for double the amount when it becomes law.

Cost to the practitioner

Anonymous | | Permalink

If Sarah's comments are true, then this is all getting ridiculous.

Typical new business:

Accountant pays for MLR checks

Bank pays for MLR checks

They may change bank/accountant, so the costs are repeated.

HMRC/government get off virtually scot free, except for the tax they lose on our increased expenses and the cost of producing all this legislation and associated manuals (and the government are the ones insisting on this procedure, so they should incur the greatest, if not all, of the cost)

The electronic verification businesses make additional money (are they owned by MP's?????)

The admin time alone makes this an expensive procedure for all concerned (except HMRC, of course). We all know how expensive it is to employ people, and to ensure all of their employment rights are upheld.

Less profitable businesses mean less employment, which means more benefits paid out ... etc, etc.

When will this government start helping small business, rather than using the fear/penalty/imprisonment axe to grind them into dust???? Are we not the 'biggest' employers in this country? Can we have a 'carrot' for a change, please!

How much

The Black Knight | | Permalink

Hi Sara

Do you know a company that does this and how much will it cost ?


Sara R's picture

How Much...

Sara R | | Permalink

Hi Kalden,

My company is an online provider of instant aml checks so that you can run the chek while your customer is on the phone or in the office. The price varies you can pay as little as £1.50 per search


as little as £1.50

Anonymous | | Permalink

You say from as little as.... what is the pricing structure?

more affordable

Anonymous | | Permalink

Surely if this service is electronic it ought to be more affordable, after all, all of this can be done in pakistan now!

New regs?

Anonymous | | Permalink

I am aware that there are regs coming in for estate agents etc in January 2010 but can you point me in the direction of the regs stating that checks need to be electronic?


pauljohnston | | Permalink

Whether we like it or not the rules are comming into force.  Whingeing about them does not help.

We tell all our clients about the checks and they will have to pay for it.  Not one person has objected to paying, except that they feel it is a waste of time.  From our point of view it means that should a "money launderer" try to become a client he will be put off by our making him/her aware that we do the check.  Others may not so use it as a positive.


Richard FTAX's picture

Legatio KYC Pricing

Richard FTAX | | Permalink

We are unaware of anyone who charges less for an AML service:

ID Checks      Price/check          Price (ex vat)

15                  £4                       £60

30                  £3                       £90

100                £1.50                  £150

300                £1.25                  £375


This includes FREE registration, and a FREE configurable Policies & Procedures document.

See or phone 0113 3508772








Sara R's picture

aml checks in pakistan

Sara R | | Permalink

How can these checks be run in Pakistan when there are 2 companies that source this information and both are based in the UK

A lot of companies tell you that they charge from 50p per check... this would be based per tab where you would have to check at least 4 tabs to make it aml compliant  (Address, Sanction, Mortality, Passport/Driving Licence) plus you would have to pay a subscription fee to use their service. With my company you pay £1.50 for the whole check where you can verify up to 15 forms of ID if you choose. This is based on buying at least 100 checks to last 12 months.


Anonymous | | Permalink

Hmmmm. Still no reference to the authority for change. We always get good notice of such changes from the ICAEW and barrages of emails selling services. So far I've seen neither........

Still no answer re legislation source ?

Anonymous | | Permalink

We have had the hard sell, disguised as being helpful. I would like to see the facts. Please quote the act and section number if this exists ?

This is not good value for money ! And I do object to additional unneccessary costs of running my business. I cannot pass these costs onto my clients (and neither should they pay). I have not seen these costs identified on any other accountants invoice. This legislation should NOT be a golden opportunity to bleed us dry !

Q ? if This company misleads as regards the legislation in this area, is this a misrepresentation to a contract ?

Misrep act 1967

Sara R's picture

Hard Sell

Sara R | | Permalink


If I was pushing for a hard sell I would be cold calling accountants going in for the sale... My understanding of forums is to help other businesses and build relationships then if you could use my services you get in contact with me. Hence the only time I mentioned costs is when I was asked...

I dont need to do this as all my customers come to me through Referals and Exhibitions. Like I said this information came through a customer who is an accountant so I thought I would let everyone know before you get companies who provide this information on the phone from 9-5 when this regulation gets put in place.



elva_w | | Permalink

I am so suprised that so many people don't know about the Anti Money Laundering regulations.

Our company's regulalatory body is HMRC. Here is the HMRC AML link: Our company paid £95 registration fee last year and £120 this year to renew with HMRC under AML. I agree that this is a rip-off but we must register or I will be personally liable.

I believe that some professional accountancy bodies may charge a fee, but whatever the case its members are still legally obliged to comply with the AML regulations. This involves carrying out risk assessments on all of your clients and checking their identy in a risk-based manner.



back to Luke

Anonymous | | Permalink

Hi Luke

Unless your original post was a lead in for then the SWAT manual is much better value for money ! I am also a small practice and have no connection to Swat whatsoever, but do use the manual which does lots more than just money laundering issues. There appears to be no requirement for electronic checks. I don't know whether they still do it but I had a copy on approval before I bought.

Luke's picture


Luke | | Permalink

to everyone for their points.  No, this was not a wind-up/intro to sell something post :-)

The SWAT money laundering procedures manual is £99+VAT whereas the Ftax KYC package for the manual and 15 ID checks is £60 + VAT.  As someone who is budget conscious and uses ftax for tax returns, I think I will go for the Ftax KYC package.  The ftax risk assessment also looks very useful and simple to do.  The ID checks are an added bonus which I may use for new clients but really I am paying the £60 for the manual.

Pretty annoying that I have to pay out for it as a tiny practictioner but hey, the ICAEW don't seem to offer a proforma...

Thanks again

Luke's picture


Luke | | Permalink

Just thought I'd update. As I said, I went ahead and bought £60 worth of checks from ftax KYC and got the policies and procedures manual thrown in.  The manual was really easy to configure and now I tick that box of having to have one.

A great bonus with buying early was that I also managed to get a free Risk Assessment tool which I have found  very easy to complete with an actions section which makes actions very easy to note and explain.  The document thankfully seems to reinforce the risk assessments I had myself already decided upon, but enable them to be properly documented for the files so I can demonstrate that I've done it properly.

I should reinforce that I have nothing to do with ftax apart from being a satisifed customer, I just thought it would be useful for small practitioners like me to know how easy it was at fairly small cost to now be confident that I can prove I am adhering to the rules properly, rather than just knowing I was conforming with the spirit of it but not quite getting round to documenting it appropriately.


Treasury view

JackHarper | | Permalink

A policy adviser at the Moneylaundering division of the Treasury has mailed me:

"Your e-mail was passed to me. I cannot immediately envisage what changes the third party involved had in mind that would effect the UK.

We will consult on the 2007 Regulations shortly, but certainly do not expect to make any changes as soon as January next year. "

HM Treasury 's Intent

Mark R Outhwaite | | Permalink

Thank you Jack.


AMLCC online product - compliance manual, training, risk assessm

amlcc | | Permalink

Hi all

We have developed an online product for accountants to assist them in their compliance with MLR2007.

The product covers the requirements of the Regulations in one simple online program. It includes;

  1. Hard copy and online compliance manual with risk assessment tables and template forms
  2. Online training modules for MLRO and staff
  3. Online risk assessments to determine the level of risk each client poses
  4. Online client verification softwareto verify personal clients
  5. Secure online storage of records
  6. Reporting function to allow staff to make internal reports to the MLRO

We currently work with a number of Supervisory Bodies who offer our product to their members.

Our product retails at £197 plus VAT. Please contact me for a discount code so you can get a 10% discount.

Any questions then please ask.




Sales opportunity

Anonymous | | Permalink

There is always a sales opportunity.

However I have always found it better to cut out the bullshit ! down load the act and guidance and read yourself

You can always knock up a few forms nice and cheap.


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