Regulations for self-employed bookkeepers

All individuals or practices offering bookkeeping, accounting or payroll services to the public are subject to the Money Laundering Regulations 2017.

Those who choose to practice without complying with these regulations risk financial penalties and/or prosecution therefore an understanding of these obligations is important if you are considering starting up your own bookkeeping business, or joining the IAB while already running your own business.

What is money laundering?

Money laundering is the process where the proceeds of crime (or funds used in terrorist activities) are made to appear legitimate.

Accountants and bookkeepers can unwittingly be used as ‘tools’ in the laundering process. In 2007 (and then updated in 2017) the Money Laundering Regulations came into law to ensure that those working within the accounting sector are made aware of the money laundering threats and their obligations in disrupting these threats.

What is an AML supervisor?

There are several obligations that the Money Laundering Regulations require of a bookkeeper or accountant but the most important is to be registered with a money laundering supervisor (also known as an anti-money laundering (AML) supervisor).

An AML supervisor is a body granted supervisory authority by Parliament in accordance with the Money Laundering Regulations 2017. There are twenty-six such supervisors within the UK. Most of these supervisors are professional associations like the IAB but the list also includes HM Revenue & Customs.

Those bookkeeping or accounting practitioners, to whom the regulations apply, who are members of a professional association (such as the IAB) must activate their AML supervision with that association by registering as a member in practice.  If you are already a member of the IAB, or considering becoming a member of the IAB, you must activate your AML supervision with the IAB by applying for an IAB practising certificate.*

Those bookkeeping or accounting practitioners, to whom the regulations apply, who chose NOT to join a professional association must appoint HM Revenue & Customs as their AML supervisor. Further information can be found at HMRC Money Laundering Regulations

* Practising certificates are issued to members and fellows. Associates will receive a Certificate of AML supervision.

Who do the regulations apply to?

The money laundering regulations apply to those persons offering bookkeeping or accounting services to members of the public on an external basis.  A more detailed explanation can be found at:

Money Laundering Regulations – who do they apply to?

How the IAB helps members to comply with the Regulations

The IAB is an AML supervisor granted supervisory authority by Parliament in accordance with the Money Laundering Regulations 2017. Therefore members of the IAB offering bookkeeping services on an external basis DO NOT need to register with HMRC for money laundering supervision, thereby saving money and time.

The IAB offers all of its members who have additionally registered for money laundering supervision, access to guidance and assistance to help you fulfil your obligations to the regulations. By registering as a member ‘in practice’ with the IAB you will also gain access to AMLCC (The Anti-Money Laundering Compliance Company), an online product that assists users in meeting the Regulation requirements, with tools such as risk assessing clients and money laundering training.  This resource is itself worth approximately twice the cost of the annual IAB AML supervision.

If you want to enquire about becoming an IAB professional member please fill in the enquiry form on the Membership enquiry page or contact the Membership team at membership@iab.org.uk  or phone +44 (0)1732 897750.

For further advice on how to apply to the IAB for AML supervision please contact the Compliance team at compliance@iab.org.uk  or phone +44 (0)1732 897750.

Late registration

It is an offence under the money laundering regulations 2017 to offer bookkeeping or accounting services to the public on an external basis without being registered for anti-money laundering supervision.

If HMRC becomes aware that a bookkeeper is offering services to the public without holding AML supervision either with it or a professional association, they can levy a fine equivalent to their annual fee, for every year the bookkeeper has practiced unsupervised.

At the IAB we also levy a late registration fee but it is capped at the equivalent of one year’s HMRC fee.

A more detailed explanation on the IAB late registration fee can be found below:

Late registration fee

If you wish to discuss whether this applies to you please contact the Compliance team at compliance@iab.org.uk  or phone +44 (0)1732 897750.

Please note that information regarding previous supervision will be collected from both existing and prospective members to facilitate this process and the IAB reserves the right to share this information with other supervisors if necessary.

General guidance on the anti-money laundering regulations

If you wish to see general guidance on money laundering regulations please follow this link to HMRC’s website HMRC Money Laundering Regulations – but please note that if you are already a member of the IAB or considering becoming a member of the IAB you should not register with HMRC for AML supervision. Instead you must activate your AML supervision with the IAB by applying for an IAB practising certificate.*

At the IAB, we follow the CCAB’s (Consultative Committee of Accountancy Bodies) anti-money laundering guidelines approved by HM Treasury. It contains everything you need to know about the legislation**. Providing the best practical help to bookkeepers and accountants, it is an invaluable resource for all our members.

Click here for a full copy of the CCAB guidance specific to the Accountancy sector.

Click here for a copy of the full Money Laundering Regulations 2017.

* Practising certificates are issued to members and fellows. Associates will receive a Certificate of AML supervision.

**Please note that the CCAB guidance has not yet been updated to reflect the changes between the 2007 and 2017 legislation. As soon as it is we shall update our website.

If you want to enquire about becoming an IAB professional member please fill in the enquiry form on the Membership enquiry page or contact the Membership team at membership@iab.org.uk or +44 (0)1732 897750.

For further advice on how to apply to the IAB for AML supervision please contact the Compliance team at compliance@iab.org.uk  or phone +44 (0)1732 897750.

How do the regulations affect IAB members?

At the IAB we refer to external bookkeepers or accountants as  being ‘in practice’. If you are an external bookkeeper and are currently (or considering becoming) a member with the IAB you are obliged to register as a member in practice with the IAB.

Once registered you will either need to apply for a practising certificate which will confer AML supervision and practice assurance upon you OR you will be required to apply for exemption from holding an IAB practising certificate as you already hold a practising certificate with another approved professional association.

If you are currently (or considering becoming) a member of the IAB you should not apply for AML supervision with HMRC. If you have already registered with HMRC for AML supervision you must still register as a member in practice with the IAB  but you must switch your supervision over to the IAB as soon as your HMRC supervision expires.

Further information for existing members can be found by logging into the IAB members area and going to the Member in practice section.

Additional fees may apply.

See also:

Important information for self-employed bookkeepers