Under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, (MLR) if you are a principal in a firm of auditors, external accountants, insolvency practitioners or tax advisers your firm must have an AML supervisor which is responsible for monitoring the firm’s compliance with the money laundering legislation. This includes sole traders and those working as self-employed consultants. It may also include subcontractors (unless you are subject to an exemption as outlined in FAQ 9 ATT here).
Your professional body will ordinarily be the firm’s AML supervisor. Where there is more than one potential professional body supervisor it is responsibility of the professional bodies to decide which is the most appropriate supervisor.
First-time registration
We recommend applying one to two months before you intend to begin trading as there is a range of documentation and information which registrants must provide as well as further checks that must be completed before final approval can be given.
There are implications where members do not register promptly (see the late registration policy and guidance below).
The AML supervision year runs from 1 June to 31 May. The fee for the 2024/25 period is £340. It will increase to £350 for the 2025/26 period.
Please email [email protected] with the following information in order to set your firm up on our system. You will then be sent a link via email to the application form and fee (to be completed online in your Portal) which begins the registration process:
- Name of ATT member
- Membership number
- Confirmation of email address
- Registered name of business
- Trading name of business (if applicable)
- Date business commenced trading or intends to commence trading
- Type of entity being registered, i.e. sole trade (self employment), practice, limited company, partnership or LLP
- Membership details of other supervisory professional bodies for all principals in the business (principal means a sole trader, equity partner in a partnership, member of a limited liability partnership or company director listed at Companies House)
- Name of previous Professional Body Supervisor (if applicable)
In order to progress your application we will also need criminality check disclosures (eg Disclosure Barring Service certificates) for all principals, beneficial owners, office holders and managers with responsibility for AML within the firm. See the Criminality Checks guidance below for further details
Once the required information has been provided your application will be reviewed. On average this takes 2 to 4 weeks but it may take longer if further information is required. If you are successful you will be sent a confirmation email stating that you have been accepted for AML supervision.
Late Registration policy and guidance
If a firm has not registered for AML supervision by the date they commence trading or the date their registration with another supervisor ceased their registration is late. Late registrations of 3 months or more will be charged the AML registration fees for all years for which it should have been registered with the ATT for AML supervision (if relevant). See late registration policy and guidance below.
| From 1 June 2022 late registrations will also be considered for referral to the Taxation Disciplinary Board. There will be an automatic referral where the registration is more than a year late. |
Please see late registration policy and guidance note for further detail.
Firms and sole practitioners providing capital allowances advice require AML supervision and should refer to the information here.
Criminality Checks
If you require further information in relation to the criminality check requirements for supervised members please see: Frequently Asked Questions – Criminality Check Requirements under MLR 2017, as amended.