Must read: Updated AASG risk outlook is here

The new accountancy AML supervisors group (AASG) risk outlook is available to read now. Here’s an overview of key updates and what to do with the information.

Here’s the updated Accountancy AML Supervisors Group (AASG) Risk Outlook PDF.

How this relates to you

Whilst undertaking the firm-wide risk assessments, firms (including sole practitioners), must take into consideration the following information that is publicly available:

• the National Risk Assessment (NRA) 2025
• AML and CTF guidance for the accountancy sector (AMLGAS (PDF))
• information provided by AAT via articles and alerts, and
• the Accountancy AML Supervisors’ Group (AASG) risk outlook (PDF).

Key updates

The risk outlook was updated in September 2025, and it provides a snapshot of emerging risks in the accountancy sector. Key updates include:

Money laundering threats, which accountants are likely to spot due to the services they provide. For example, tax advice – tax evasion; payroll – modern slavery and human trafficking.

Updated definition of a wealthy individuals (those earning more than £200,000 a year, or with assets over £2 million, in any of the last three years).

Additional links added – the FCA has published guidance (PDF) about the enhanced customer due diligence measures for Politically Exposed Persons (PEPs). The starting point for the risk assessment of a UK PEP (or their family members and known close associates) is that they present a lower level of risk than a non-domestic PEP.

The NCA has published indicators of modern slavery and human trafficking in the accountancy sector.

Next steps

Review the risk outlook in full and follow the below process:

• identify the money laundering risks that your firm faces
• assess each identified risk
• where required, implement appropriate mitigation or conduct EDD.

Remember to keep your firm wide risk up to date and ensure an appropriate audit trail by documenting these steps.

If you know, suspect or have reasonable grounds for knowing or suspecting that a person is engaged in money laundering or dealing in criminal property, you must submit a  Suspicious Activity Report (SAR) via SAR portal to the UK Intelligence Finance Unit (UKFIU).

Further guidance and support on risk management and other components of Money Laundering Regulations compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email [email protected].

Read about how taking action can help free modern slaves.

Future of supervision

On 21 October 2025, the Government confirmed that the AML supervision for accountancy, legal and Trust and Company Service Provider sectors will move to a single professional services supervisor (SPSS), specifically the Financial Conduct Authority.

While this is a big shift, implementation is likely to take years. In the meantime, AAT will continue as the AML supervisor for our licensed members and carry out our normal responsibilities, including Practice Assurance Reviews and risk assessment activities. Therefore, our members must ensure full compliance with the MLR 2017. More on the consultation response can be found here.

Further guidance and support on risk management and other components of Money Laundering Regulations compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email at [email protected].

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