Accountants & Accounting Firms FAQs
Yes. If your firm helps clients with services like company formation, trust setup, managing funds, or real estate transactions, you’re likely considered a “designated non-financial business” (DNFBP) under AML laws. This means you must perform KYC, monitor risk, and follow AML and sanctions rules.
Accountants should:
- Collect and verify valid ID and address documents
- Identify beneficial owners for companies or trusts
- Understand the purpose of the engagement
- Assess source of funds or wealth where needed
This forms part of a risk-based onboarding process.
Clients may be sanctioned individuals or linked to restricted jurisdictions. Accountants must screen clients and entities against global and local watchlists (e.g. UN, OFAC, EU). This helps avoid unintentional involvement in financial crime or prohibited transactions.
Risk assessment involves scoring each client based on:
- Type of service (e.g. tax filing vs shell company setup)
- Jurisdiction (domestic vs offshore)
- Client profile (PEP, high cash business, etc.)
This risk level dictates the depth of due diligence required—Simplified, Standard, or Enhanced (EDD).
- Clients refusing to provide full information
- Payments from third parties not listed in the engagement
- Use of multiple entities with unclear relationships
- Requests for nominee directors or complex structures
- Links to sanctioned countries or politically exposed persons
Yes. Even small or solo accounting firms must comply with AML laws if they help clients with things like company formation, tax structuring, or managing funds. Regulators in countries like Nigeria, Kenya, India, and the Philippines include accountants as “designated non-financial businesses” (DNFBPs).
But the approach can be scaled. Small or solo practices must still:
- Conduct risk-based KYC
- Keep records of due diligence
- Report suspicious activity
- Screen clients for sanctions
Anqa’s platform helps firms right-size their compliance without excessive overhead.
Risk assessments and KYC should be reviewed:
- Periodically (e.g. every 12–24 months)
- When there’s a significant change in the client’s business or ownership
- When red flags or new risks emerge
Ongoing monitoring is a key part of AML compliance.
Anqa offers:
- Automated ID verification and KYC workflows
- Built-in sanctions and PEP screening
- Risk scoring templates tailored for professional services
- Simple audit-ready logs for regulatory reporting
Accountants must:
- Identify and verify clients (Customer Due Diligence)
- Assess and document AML risk
- Report suspicious transactions
- Maintain records for 5+ years
- Train staff on compliance
An AML programme doesn’t need to be complex—but it must be active and up to date.
An AML risk assessment helps accountants understand where their business is exposed to money laundering risks. You’ll assess client types, services offered, countries involved, and transaction patterns. This risk rating then shapes your CDD and ongoing monitoring strategy.
Small firms can start with basic steps:
- Collect national ID and proof of address
- Ask for source of funds for high-value or unusual transactions
- Check for sanctions or politically exposed persons (PEPs)
- Use free or affordable tools like Anqa to manage checks and logs
Examples include:
- Clients unwilling to share information
- Complex ownership structures with no clear purpose
- Large cash payments or cryptocurrency use
- Services paid for by third parties
- Frequent changes in instructions or jurisdictions