Your firm may apply to be supervised by the ATT if at least one principal in the firm is a member of the ATT. To register, please complete the application form below.
For firms with 50 principals or fewer there is an annual fee of £120 per legal entity. Firms with more than 50 principals should ml [at] att.org.uk (subject: AML%20-%20Firms%20with%20more%20than%2050%20principals) (contact the ATT) for further details.
By applying to be supervised by the ATT, your firm undertakes to:
- Comply with the UK Anti-Money Laundering legislation. A brief outline of your firm's obligations under the Money Laundering Regulations 2007 can be found below.
- Conduct its practice in accordance with the laws of the ATT with particular regard to the Professional Rules and Practice Guidelines.
- Complete and submit an annual return, which will include questions about your firm's compliance with the Anti-Money Laundering legislation. You will be contacted in March/April each year about this.
- Permit and co-operate with inspection visits by the ATT or its authorised representatives.
- Notify the ATT of any relevant changes in the details supplied about the firm within 30 days of the changes taking place. For example if there is a change in the principals of the firm, particularly if the firm no longer has a principal who is a member of ATT.
As a supervisory authority, the ATT will:
- Provide guidance on the practical application of the UK Anti-Money Laundering legislation. Guidance for the Tax Sector has been drafted in conjunction with the Consultative Committee of Accountancy Bodies; is Treasury-approved, and can be found here. See also the guidance issued by the Joint Money Laundering Steering Group.
Provide helpline support by telephone 020 7340 0550 or ml [at] att.org.uk (subject: AML%20query) (email us). Please note that the helpline cannot and will not provide definitive legal advice.
Issue and review an annual return to be completed by the registered firm.
- The ATT may visit a firm with a view to discussing and inspecting its AML compliance procedures and records.
- Participate in the Anti-Money Laundering Supervisors' Forum to keep abreast of new developments and share best practice with fellow supervisors.
How will my clients know that I am supervised for Anti-Money Laundering compliance?
The firm may use the following wording on its practice stationery or website:
'Supervised by the ATT for the purposes of Anti-Money Laundering legislation'.
What happens if the firm does not comply with the ATT Anti-Money Laundering compliance scheme rules?
In cases of relatively minor non-compliance the ATT would hope to be able to resolve such matters on an informal basis. More serious and/or repeated failures to comply will be referred to the Taxation Disciplinary Board Ltd, which will investigate and take disciplinary action as appropriate. The ATT will in general follow the approach agreed by the Supervisory Authorities in the tax and accounting sector.
If in the course of its role as a supervisory authority the ATT 'knows or suspects that a person is or has engaged in money laundering or terrorist financing it must promptly inform the National Crime Agency'.
What happens if the only principal who is a member of the ATT leaves and the firm no longer has any members of the ATT at principal level?
The firm should notify the ATT straight away (and in any event no later than 30 days after the principal leaves). The ATT will advise whether the firm will be de-registered or will be allowed to remain on the ATT register until the next renewal of registration. If the firm is de-registered it will have to register with another supervisory authority. HM Revenue & Customs are the default supervisory authority for tax practitioners.