Anti-money laundering

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Anti-money laundering

Verifying beneficial owners

9 Oct 2025
aat comment

Ensuring consistency in the accountancy sector.

All firms (including sole practitioners) must identify and take reasonable measures to verify the identity of the beneficial owner.

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What is a beneficial owner

Regulation 5 of the Money Laundering Regulations 2017, states that a beneficial owner is:

  • any individual who exercises ultimate control over the management of the body corporate;
  • any individual who ultimately owns or controls (in each case whether directly or indirectly), including through bearer share holdings or by other means, more than 25% of the shares or voting rights in the body corporate; or
  • an individual who controls the body corporate.

Beneficial owner is always a natural person, i.e. a human being.

How to identify a beneficial owner

Identification and verification of a beneficial owner can be difficult at times. However, the Accountancy AML Supervisors Group’s (AASG) guidance (PDF) is now available on AAT’s website. Please ensure you read it alongside AML guidance for the accountancy sector (AMLGAS (PDF)) . In particular, please see:

  • pages 46-50 – helps to establish who the beneficial owners could be for a variety of entities;
  • Appendix E – provides case studies for each of the client types;
  • Annex B.1.4 – sets out the sources of evidence that may be used to verify the identity of natural persons.

Next steps

Ensure you follow the above-mentioned guidance when undertaking and documenting initial and ongoing Client Due Diligence measures.

Remember, money laundering is never a victimless crime. 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].

Protect yourself with AML training

Join this vital webinar on key AML updates for regulated firms.

Sign up now

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].

AAT Comment offers news and opinion on the world of business and finance from the Association of Accounting Technicians.

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