UKFIU podcast on Illicit finance in Organised Immigration Crime

Listen to the latest UKFIU podcast to find out about the current threat, and how IVTS plays a role in enabling this crime.

In this episode, panellists from the National Crime Agency (NCA) address the illicit finance angle of Organised Immigration Crime (OIC). Panellists explain the current threat picture, how Informal Value Transfer Systems (IVTS) play a role in enabling this crime and the actions being taken by the NCA to disrupt organised crime groups involved in OIC.

Listen to Episode 24 now.

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].

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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].

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.

Protect yourself with AML training

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

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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:

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].

Protect yourself with AML training

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

Sign up now

Should accountants be worried about AI this tax season?

Over half of UK taxpayers plan to use AI to complete their self-assessment tax return. Do accountants need to be concerned about how their clients are using it?

A TaxFix study found that 59% of UK taxpayers are using AI to help them complete their self-assessment tax return for HMRC’s 31 January 2026 deadline. The study also asked accountants about their concerns, which include AI’s incomplete advice (73%), inability to handle nuance (62%) and its lack of UK-specific information (52%).

Are accountants seeing clients relying more on AI for managing their tax affairs, or turning up to appointments armed with AI-generated information? What is the view among UK accountants of the impact of AI on their work and their client interactions?

AAT Connect is back

Join us for our biggest in-person member event of the year on Friday 7 November at AAT Connect.

Find out more

We welcome clients doing research themselves

Simon Antonis, Founder and Director, Simon Maughan & Co

AI is giving much more detailed and customised responses than search engines, which most clients have been using for many years. But AI often misses important areas that are relevant to their situation, and unless you know what questions to ask to challenge AI, those gaps stay hidden. AI can’t always reference all the relevant regulations, latest practices, or legal precedents, and it definitely can’t apply these to specific circumstances.

But we actually welcome it when clients do their research, whether through AI, search engines, or chatting with friends and family. We can dive straight into providing tailored advice while making sure everything stays within the law. This research process often helps clients see these limitations and complexities for themselves.

AI is a useful tool for summarising research and great for marketing – and our website development team uses it too. The key thing clients often discover is that tax advice isn’t just about knowing the rules. It’s about understanding how those rules interact with your specific situation, your goals, and sometimes even your industry. That’s where expertise and experience really count.

Verdict: We welcome the client interactions AI creates; it shows where expertise and experience really count.

It’s our job to verify information for clients

Stephanie Marshall, author and CEO, A B C S UK

As accountants, we’ve heard “my mate Dave down the pub says…” for years. Generative AI tools are simply the modern version of Dave down the pub or a quick Google. I haven’t seen an increase in these questions, and I suspect those asking generative AI for tax advice often do not have an accountant to support them.

Accountants don’t need to fear generative AI. Due to the unique nature of each taxpayer and company’s circumstances, generative AI would need to be far more sophisticated before it could accurately provide tax advice correctly and confidently.

If clients are bringing AI-generated information to a meeting, it’s our job as accountants to verify it. The relationship built with a client means they should trust your expertise over AI every time.

AI is great for pulling together information such as current HMRC guidance, tax and VAT thresholds and allowable expenses, as a useful starting point. But as personal circumstances and business structures vary, applying tax advice to the client’s position is where a qualified human accountant is needed.

Verdict: There’s no need to fear AI; the human touch is still essential, and relationship-building should mean clients trust your expertise.

No substitute for understanding a client’s situation or the finer points of tax law

Sean Farnell, Partner, Burgis & Bullock

We’re starting to see clients arrive with information they’ve picked up from AI tools, though in truth, most still turn to Google for quick answers. For straightforward questions, AI can sometimes provide a decent steer. But as soon as things get more complicated, or there are grey areas in the legislation, the answers can be wide of the mark. There’s no substitute for understanding a client’s situation or the finer points of tax law.

We’re only just starting to use AI in the firm, and we’re very careful about how and where it’s applied. Confidentiality is non-negotiable, and everything is subject to proper review. AI is helpful for sifting through large volumes of data and spotting patterns, but it can’t interpret context or apply judgement in the way a professional can.

AI isn’t going away. The fact that more people have access to information is, on balance, a good thing. But there’s a real risk in relying on generic or unregulated advice, so professional standards and regulated advice matter more than ever.

The best results will come from accountants and AI working together, using technology to improve efficiency and insight, anchored by professional expertise and a proper understanding of each client’s needs. Humanising the numbers will increasingly be what clients are willing to pay for, with soft skills increasingly at a premium.

Verdict: AI can’t replace accountants, and best results will come from us working with technology.

Models built on verified, expert-curated data are the real game-changers

Ben Chaplin, Chief Financial Officer, Peninsula Group

Accountants and professional bodies are watching developments with interest and considering how best to harness the technology to improve efficiency, balanced with risk. Using off-the-shelf AI can introduce serious risks such as outdated or incorrect data, fabricated – hallucinated – answers and unverified output.

Principles set out in our ethical and auditing standards stand more than ever for finance professionals. Apply analytical rigour and professional scepticism, consult appropriately and ultimately always validate the source of any information. As with any technological development, different forms of AI are ultimately just another tool we can choose to use, subject to compliance with professional standards. All of us need to consider the sustainability impact and mitigate the risks to protect ourselves and our clients.

The real game-changer is models built on verified, expert-curated data, rather than the fastest internet scrape. We use a solution that leverages decades of expert-written tax, audit and accounting content, providing responses with links to statutes, case law and detailed analysis, ensuring answers are accurate, reliable and verifiable.

Verdict: Seek out the best models, be rigorous and professionally sceptical and always validate AI-generated information.

Accountants need to be able to explain why AI’s information is wrong

Arj Kumar, Founder, Taxd

Typically, accountants build relationships with clients and learn a lot about them. This gives them unparalleled insights into their long-term goals, priorities and financial situation. Unlike AI, accountants’ view of their clients’ money is often shaped by context and by years of relationship building.

This isn’t something which AI can do to a satisfactory level. However, this may be possible in future. As it stands, AI can effectively be used for straightforward questions, such as ‘how to invest £10,000 every year’.

But for long-term financial planning and complex situations, traditional financial advisors will be preferred by the majority. For trained accountants, it’s frustrating to see clients using AI, receiving incorrect information and treating this advice as gospel. It’s important for advisers to ensure their clients are aware of the risks.

Now, many clients come equipped with advice from GenAI. Although this can be a good start, this sometimes can lead to wrong information being shared. To counter potential mistakes, accountants need to be able to explain why AI can be wrong and back up their responses with evidence. This has fundamentally flipped the relationship between accountants and clients.

AI can be used to provide confidence or as extra assurance. In most cases where the advice needed isn’t too complicated, AI can draft things up and get 99% of what the recommendation would be. This can be reviewed by a human to remove any errors or unhelpful advice.

If firms move fully to AI for advice, they will need to consider insurance to cover liabilities that could arise if inappropriate AI-driven responses are acted on. There is hesitation, but we are seeing more uptake in AI adoption as providers look to remain competitive.

Verdict: Unlike AI, accountants’ view of client money is shaped by context and relationship building.

AAT Connect is back

Join us for our biggest in-person member event of the year on Friday 7 November at AAT Connect.

Find out more

AAT Disciplinary, Professional Standards and Regulation update

New version of Indicative Sanctions Guidance for members to aware of.

AAT recently published a new Indicative Sanctions Guidance document (PDF). The guidance outlines how sanctions will be determined in disciplinary cases involving our members and is used by AAT’s Investigations Team, Disciplinary Tribunal Committee and Appeal Committee when considering disciplinary matters. It was presented to the Professional Standards and Regulation Board (PRSC) for final approval at their meeting in September 2025.

The changes

The proposed changes are a result of a review of the existing guidance where stakeholder insight suggested clarity was required.

These amendments are also intended to ensure alignment with the evolving regulatory expectations placed on AAT as a Professional Body Supervisor, thereby enabling us to fulfil our enforcement duties under Regulation 49(1)(d) of the Money Laundering Regulations 2017. This is achieved by AAT ensuring that any contravention of a relevant AML requirement, the member be liable to effective, proportionate and dissuasive disciplinary measures. 

Furthermore, these changes aim to support public confidence and to maintain a dissuasive, proportional, and fair application of our disciplinary measures.

This is an opportunity for all members to read the guidance in full and familiarise themselves with our compliance requirements.

If you have any questions, or have an open disciplinary case that you would like to discuss, please contact the Investigations and Disciplinary team at [email protected].

AAT sanctions for AML breaches

PII: avoiding non-compliance sanctions and penalties

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].

What to do if you need help with your mental health

A quarter of us will experience mental health issues at some point in our lives. But what signs should you look out for that your mental health is suffering?

Who should you turn to for help with your mental health, both at work and outside of work? Read on to find out.

What’s the problem?

A study by the Chartered Institute of Personnel and Development estimates that mental ill health costs UK employers between £33 billion and £42 billion a year. But it’s not just about money. The study looked at the impact of poor mental health, finding that 37% of sufferers are more likely to get into conflict with their colleagues and 80% find it hard to concentrate.

Is there a stigma about mental health?

Amanda Griffiths is Professor of Occupational Health Psychology in the University of Nottingham’s School of Medicine.  Professor Griffiths says: ‘We are much more aware now about mental health and how common it is for employees to have problems – both those that are caused by work and those that are non-work related. There is less of a stigma, but this will vary as to what type of organisation you work in. Some organisations have a more positive culture where seeking help is OK’.  

Making mental health a priority

Emma Mamo is head of workplace wellbeing at Mind. She says: ‘Over the last few years, we’ve seen a huge increase in the number of employers making the mental health of their staff a priority. This is largely due to heightened awareness and reduced stigma surrounding mental health, thanks in part to movements like Time to Change, run jointly by Mind and Rethink Mental Illness’.

However, Mamo adds that while there has ‘undoubtedly been a positive shift in societal and employers towards those of us with mental health problems, we still hear from people who have been disciplined, demoted or even dismissed as a result of disclosing. This isn’t good enough’.

What are the warning signs?

There’s helpful advice here. Some early indicators of possible poor mental health are feeling negative, being indecisive, feelings of isolation or nerves. If your drinking or eating habits have changed or you are smoking or drinking to help you cope or have difficulty sleeping these can be indicators too. 

Extra support in the workplace

Awareness of your mental health needs is vital: you wouldn’t ignore a physical illness so don’t do so with a mental condition.

It’s also important to remember that we are all different and workplaces should be inclusive and respond to everyone’s needs. ‘Disabled people can and do make a valuable contribution to the workplace’ adds Mamo. ‘But some may need extra support to help them overcome barriers and thrive in their roles’.

It’s also worth remembering that having AAT qualifications makes it easy to work flexibly which can be helpful in managing your mental health needs.

What should you do?

Talk to someone if you’re worried about your mental health. Ideally, approach your line manager or if you’d rather, human resources –and do it sooner rather than later.

Louise Aston is Community Well-being Director for Business in the Community. She says: ‘The key thing is that mental health needs to be given the same parity as physical health. If an employee had, for example, a broken ankle then you would expect an employer to make adjustments for them.

Employers should be similarly accommodating to the needs of those with mental health problems: that could mean introducing training for workplace adjustments and work modifications, including changes to tasks and phased returns, for example’. There are some examples of how employers deal with mental health issues here.

What can your employer do?

Changes to working hours, roles, responsibilities and place of work could help. ‘For example, if your medication makes you drowsy in the mornings, it would be reasonable for your employer to let you start and finish your working day later’ adds Mamo.

‘It’s in the employers’ interests to invest in the mental health of their staff. Offering things like generous annual leave, flexible working hours, free fruit, subsidised exercise classes and Employee Assistant Programmes (24 hour telephone support) can all make a difference’.

Leading from the top

If you are the boss or a line manager, then if you suffer from poor mental health then share that with your colleagues. Aston explains: ‘Businesses have to make it clear that it is OK not to be OK and message should come from the top.

It was so important when Lloyds Banking Group chief executive Antonio Horta-Osario disclosed that how restoring Lloyds Bank’s fortunes almost shattered his mental health and why he’s on a mission to end the stigma of workplace stress. It’s a great example of how an organisation can champion mental health from the top’. 

Mental health embedded in company culture

Aston adds: ‘It is so important that mental health at work is embedded in the organisation’s culture through operational procedures and accountability. Measurement and monitoring is also crucial as we know ‘what gets measured gets managed’. In the interests of transparency and accountability, employers should publicly report on mental health and wellbeing.

It is all about leadership. Lots of organisations make promises but what they need to is to change their approach. This is not about ticking boxes’. She adds: ‘It is important that there is a culture of openness, that mental health issues are talked about in a supportive environment of inclusivity’.

And employers being positive about mental health issues can see a difference in the bottom line: a report by Deloitte found that employers saw a return on investment of between £1.50 and £9 for every £1 spent on workplace well-being interventions.

Summary

We are all different and a 21st century workplace will reflect that. Mental illness should be treated on a par with physical conditions and your employer should accommodate and respond to your needs. But they do need to know about it first.

If you have mental health issues then approach your line manager. Or if you’d rather, go to your union representative or HR department. There’s nothing to be gained from ignoring your condition – indeed it could make it worse.

Further reading

From AAT student to AAT member: the next steps for your career

For many newly qualified accountants, their AAT journey doesn’t end with that final exam result; it’s just the beginning of an exciting new chapter as an AAT member.

You’ve put the hard work in, passed your exams and got your AAT qualification, but then what? AAT opens up a huge amount of doors in the world of accountancy and finance, including the chance to take the next step in your career as an AAT member.

Why make the transition from student to member?

The decision to continue as an AAT member after qualifying might seem obvious, but it’s worth understanding exactly what you’re gaining. Grace Hardy, MAAT, who runs her own accounting practice, wanted to remain as an AAT member to continue enjoying its social perks.

“One of the reasons I wanted to stay on and be a member is the community aspects,” she said. “Everyone is literally so nice. When I post on social media that I’m at AAT events, speaking on panels, or meeting up with people in the community, that gives me more credibility and trust with my clients and also future potential clients as well.

“Every year, I make a real effort to go and see everyone and catch up. I go to a lot of the accounting expos like Accountex London and the Finance, Accounting & Bookkeeping Show (FAB), to meet up with members in person, as well as AAT Connect.”

One of the most immediate benefits of AAT membership is the professional recognition it brings. Those designatory letters after your name – MAAT (Member of the Association of Accounting Technicians) – carry real weight in the industry.

Grace said: “Some clients don’t understand accounting qualifications, but they see the letters after your name and know that you’ve got a good qualification.”

Andy Sullivan, FMAAT (Fellow Member of AAT – which is a higher designation than MAAT and awarded to long-standing members who demonstrate commitment to the profession), who runs his own practice, Complete HQ, and mentors AAT trainees, emphasises thinks that for employers and clients alike, AAT membership demonstrates that you’re maintaining professional standards and staying current with industry developments.

He said: “One of the big things is being able to demonstrate to prospective clients that you’ve got that level of qualification and that you’re maintaining on those ongoing standards, because to remain a member is not just a case of completing the exam and getting a qualification. You have to do the ongoing CPD and various ongoing checks.”

AAT membership is a gateway to greater opportunities

AAT has long been recognised as the foundational gateway into the accounting industry. It’s the qualification that opens doors, whether you’re looking to work in practice, industry, or start your own business. The practical, hands-on approach of AAT training means you’re job-ready from day one, and membership keeps those doors wide open.

Grace said: “I was finishing up my Level 4, and I saw the AAT Be Your Own Boss campaign. It wasn’t until then that I realised you could start your own practice with your Level 4 qualification. I thought you had to progress to chartered, ACA or ACCA.” This opened up possibilities Grace hadn’t even considered, and she’s now the award-winning founder of Hardy Accounting.

Continuous learning through CPD and resources

Professional development doesn’t stop when you qualify – in fact, it becomes even more important. AAT membership gives you access to a wealth of learning resources through the Learning Portal, ensuring you can keep your skills sharp and stay ahead of industry changes. The best thing about these resources is their flexibility. Whether you prefer structured courses or bite-sized learning, there’s something to fit around your work schedule and learning style.

Beyond formal CPD, AAT members have exclusive access to the Knowledge Hub, a comprehensive resource that provides technical guidance, industry insights and practical tools. This platform keeps you connected to the latest developments in accounting standards, tax changes and best practice guidance – all the essential knowledge for any accounting professional.

Regulatory benefits for practice and opening doors

If you’re planning to work in practice or set up your own firm, AAT membership offers practical regulatory advantages. As Andy explains, “For us, being in practice, another benefit of being an AAT member is that they deal with your anti-money laundering compliance. We have to comply with AML Rules, and AAT are our regulatory and supervisory body.”

This support alleviates a significant administrative burden, ensuring you meet your professional obligations.

AAT membership also keeps your options open for further professional development. Many chartered accountancy qualifications offer exemptions for AAT members, recognising the solid foundation your qualification provides. Whether you’re considering ACCA, CIMA, or other professional qualifications, your AAT membership puts you in a strong position to progress.

The investment that pays dividends

Continuing as an AAT member after qualifying is more than just maintaining a qualification – it’s an investment in your ongoing professional development and career prospects. The combination of credibility, resources, community support, and practical benefits creates a platform for long-term success in the accounting profession.

As Grace sums up, “Everyone is delightful. They have been so supportive of my journey, and I’ve had so many opportunities that I don’t think I would get otherwise.”

So as you celebrate your qualification success, consider making AAT membership your next step. It’s not just about the letters after your name; it’s about joining a community that will support your career for years to come.

Further reading

AAT on a budget: how to manage study costs, from textbooks to exam fees

Why AI is making accountancy exciting for a new generation

AAT members discuss how they nurture strong client relationships

How you can help modern slaves

Modern slavery is a very real problem in the UK – as one AAT student experienced for herself. Accountants are at the front line for spotting this kind of abuse, so need to be vigilant of the signs. 

One member’s story

Just over six years ago, Deepika AATQB and two of her three children were flown from her home in India to the UK to visit her husband’s relatives. She was told it would be a ‘holiday’. 

But on arrival, they were met by her husband’s uncle and aunt who confiscated their documents, passports and money.

Ethics and the digital world

Visit the AAT Lifelong Learning Portal to find out more about the ethical impact of digital technologies on you as an accountant (log in to view).

Learn more

She was forced to work every day from 6:30 in the morning until 11:30 at night, cooking, cleaning, gardening and other domestic tasks. Her children (four and 12 at the time) were sometimes forced to work, too. 

“They told me they had paid my husband and I to serve them for seven years,” Deepika recalls. “My other child had been kept in India to ensure I behaved. My husband used to phone and tell me that if I returned, he would kill me and the children.” 

There was just one mattress for the three of them and they were fed on leftovers. They endured physical and psychological abuse. “They locked my older daughter in a room for a few months with limited food at one point and my son was locked in a store cupboard,” says Deepika. “We were refused medical care and we weren’t allowed to go out, unless I was taking the children to and from school, but I was always watched. It was continuous abuse for two years.”

How one intervention made a difference

Deepika is able to share her story with AAT because she managed to escape after a local resident grew suspicious of her situation and smuggled her a note with contact details of organisations who could help her. 

Six years on and Deepika and her children are safe. Although Deepika is currently unable to work because she is still in the process of seeking asylum, she volunteers at a local foodbank and her son’s school, and she has finished AAT Level 3 with the hope of one day becoming a licensed accountant. 

Deepika’s story serves as a reminder that raising one concern can change a life. 

“While a lot of the time, modern slavery suspicions might be unfounded, it’s important to remember that some of the time those suspicions will be correct,” says Julia Penny, chair of ICAEW Ethics Advisory Committee and principal of JS Penny Ltd, which provides anti-money laundering procedure training. 

Financial exploitation is increasing

Anti-slavery charity Unseen estimates that 122,000 people in the UK are currently in modern slavery. 

According to Justine Carter, Deputy CEO at Unseen, there’s been an ‘uptick’ in financial exploitation where people work for a genuine business, but wages are taken from them once they’ve been paid. 

“These situations are becoming more common,” she says. “There is often an individual on the outside who is commanding control over somebody’s finances, threatening them and having a hold over their life.”

Why you?

AAT members are crucial in identifying modern slavery, although the connection between the role of an accountant and modern slavery might not be obvious to begin with.

By promoting and advocating for an ethical and transparent culture across all your business relationships, and implementing robust due diligence systems and controls, you can identify activities associated with modern slavery and human trafficking. It is extremely important that members stay up to date with global regulations and reporting requirements. 

The signs to watch out for

Accountants should look for:

  • Payroll anomalies
  • Complex supply chains
  • Shell suppliers
  • Inconsistent invoices
  • Large business operations with significantly low labour costs

In a workplace setting, it can be very difficult to spot the signs of modern slavery, but not impossible. “Some signs might be similar to domestic abuse,” says Julia. “They might be cagey or look like they’re trying to hide bruises. Maybe they are always dropped off and picked up or they’re overly anxious about leaving on time. Maybe they never join after work drinks and seem reluctant to socialise with colleagues. They might keep their head down and say very little at work.” 

As well as being aware of signs of modern slavery, accountants should be on the lookout for issues among their client base, too. Although some sectors are more high risk than others, no sector or business is immune. 

Julia highlights the importance of client due diligence (CDD). “What is the nature of the business? Is it a high-risk business for money laundering?  Is it a business which doesn’t require specific qualifications or where you can interchange people quickly? Ask yourself, ‘could this nature of client be used for modern slavery?’”

Nail bars are well-known money laundering environments for example, as well as some agricultural businesses where workers live in caravans in the fields.

Payroll information can give clues too. It may look legitimate at first glance, set up to look like payroll, but wages may be going back to the perpetrators either by disguised umbrella companies or false agencies.  

If you have staff members, ensure that they are trained in how to spot red flags. The NCA has produced a document on Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector.

What actions you can take

So what’s the advice if you suspect modern slavery? 

If you have knowledge or suspicion of money laundering, you must submit an internal Suspicious Activity Report (SAR) to your Money Laundering Reporting Officer (MLRO). 

The MLRO will then assess whether an external SAR is required to the UKFIU. Failure to submit either an internal or external SAR once you have knowledge or reasonable grounds to know or suspect money laundering, is a criminal offence. 

When submitting a SAR to the UKFIU, use the following glossary code: XXMSHTXX. This PDF from the NCA contains guidance on submitting better quality SARs.  

To report any suspicions about modern slavery, you can also call Unseen’s Modern Slavery Helpline, open 365 days a year:  08000 121 700

If you are concerned that victims are at immediate risk of harm, call the police on 999

Justine cautions against taking ‘obvious action’ which might compromise a person’s safety but instead, giving someone space and time to talk about what’s happening, without arousing suspicion. 

“There also needs to be clear escalation routes and mechanisms where individuals are given advice, help, support and next steps,” she says. “This ensures the business fulfil their duty of care obligations by providing the individual the opportunity to get help and support.” 

“Modern slavery is a constantly evolving picture, so businesses need to understand that whatever you check today might not necessarily be what you need to check tomorrow,” says Justine. “We just need to make sure that we don’t take our foot off the pedal.”

Positive outcomes

For people like Deepika, the traumatic memories of slavery will stay with her forever. But it took just one person to act carefully on a suspicion to save Deepika and her children. 

“I kept telling myself, they can keep my documents and my freedom, but they can’t keep my knowledge, my identity or my inner fight.”

One result of that inner fight was Deepika’s nomination for an Triumph Award, which is given to members who have overcome challenges and obstacles, at the AAT Impact Awards in November 2024.

Deepika’s daughter (now 18) has got a scholarship in engineering while her son (now 10) wants to be an astronaut when he grows up.

Useful resources 

Some accountants find Anti-Money Laundering (AML) and compliance stressful, or view it as a tickbox exercise. But both are essential because accountants and bookkeepers are in a very powerful position to spot and help survivors of modern slavery and other abuse – money laundering is never a victimless crime. 

AAT has a comprehensive range of resources on Standards and Requirements for you to use, including information on CDD, Suspicious Activity Reporting (SARs) and red flag indicators.

Here is AAT’s ethics page.

Learn how to report AAT’s supervised members here.

AAT Comment also features guidance on AML and compliance. 

The AASG risk outlook (PDF) sets out the key risks and red-flag indicators relevant to the accountancy sector, which covers modern slavery.

THEMIS Knowledge offers free digital learning on the subject, aimed at financial institutions. 

Ethics and the digital world

Visit the AAT Lifelong Learning Portal to find out more about the ethical impact of digital technologies on you as an accountant (log in to view).

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SMEs can only benefit from audit market changes

Audits have many benefits, providing detailed overviews of business health. However, ISAs are hard to scale and the process can be onerous for small and medium enterprises.

The Financial Reporting Council (FRC) recently pinpointed several challenges affecting the SME audit market. It has lauched a consultation on a Practice Note to support auditors as they apply International Standards on Auditing (ISAs) UK when auditing smaller and/or less complex entities.

But while the regulator’s remedy in the form of a new Practice Note providing guidance is a welcome step, it still has a way to go to address auditors’ concerns.

Findings from the FRC’s study into the SME audit market published in July highlighted widespread concerns among auditors of a lack of scalability and proportionality in applying International Standards on Auditing (ISAs) that do not meet the needs of smaller businesses.

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Fear of failure to comply

Steve Collings, a director at Leavitt Walmsley Associates, says the current model for SME audits in terms of cost and efficiency is “not particularly sustainable at the moment because the model is a ‘one-size-fits-all’ approach to auditing.”

“Very few practitioners are aware that the ISAs (UK) are scalable and where they do become aware of the scalability provisions, there is nervousness in scaling them to fit an SME client,” Collings says.

This, he says, is “most likely due to fear of not complying with the ISAs (UK) and receiving criticism from a professional body monitoring inspector.

Additional workload is a drag

The FRC found that many smaller audit firms believe that regulators expect them to do unnecessary work and that the supervisory environment “prioritises compliance and exhaustive documentation over auditors’ professional judgment.”

Therefore, audits, irrespective of size and complexity, and whether they are statutory audits or contractually agreed work relating to non-statutory audits, were expected to meet the same standards and were inspected in the same way.

Shakeups could help

A more proportionate approach to audit supervision for lower risk and smaller audits would ease pressure on the SME market by reducing costs and encouraging innovation by audit firms and smaller practitioners.

“As SMEs make up much of the marketplace, it’s important to determine the audit approaches that suit them best. While efficiency is important, maintaining a robust and reliable audit must remain the top priority”, Kate Taylor, an audit partner at DSG Chartered Accountants, says.

Consulting on auditing guidance

To assist auditors, the FRC is consulting on a Practice Note published alongside the study to help firms apply ISAs more effectively when auditing smaller or less complex entities.

Typically, smaller and less complex entities are those which have

  • ownership concentrated in a small number of individuals
  • operations with few sources of income
  • simple internal controls and business processes.

The guidance focuses on scalability, allowing auditors to tailor their approach when auditing smaller entities that often have simpler business models, fewer complex transactions and different risk profiles compared to large corporations.

It promoted a risk-based audit approach that, along with the scalability provisions in ISAs (UK), the FRC hopes will allow for the better tailoring of an audit to an audited entity and more efficient audit approach.

Paul Wilson, Policy Director at the Federation of Small Businesses, says the FRC has made several “sensible and practical suggestions to bear down on regulatory costs for SMEs”.

“Small businesses have a tendency to over-comply when they are unsure how rules should be interpreted, so extra guidance on what compliance could look like should avoid wasted time and help cut costs,” Wilson says

Practice Note details

The Practice Note, which is open for consultation until October, provides guidance for planning an audit of financial statements, including determining materiality and the use of experts.

It also outlines the overall approach to risk assessments, which are a fundamental aspect of any audit and the primary method to deliver a robust but proportionate audit focused on the key risks relevant to the financial statements of a specific entity.

 “When auditing SMEs, the process should be tailored to their specific needs. Effective planning is essential to identify key risk areas early, so auditors can allocate time where it delivers the most value,” Taylor says. “This allows efficiencies to be achieved by reducing focus on areas of lower risk without compromising audit quality.”

Materiality informs the entire audit, from the risk assessment to the design of responses to the evaluation of misstatements. So, setting an appropriate materiality is therefore key to the proportionality of the audit.

“It is based on risk assessment,” Collings explains. “If I am auditing a particularly complex group, for example, I may use more than one performance materiality level for specific aspects of the group. I might also decide to use other elements of the financial statements for setting materiality, based on risk.”

Risk of material misstatement

It is important to remember that the objective of the auditor is the same regardless of the nature of the audit: to identify and assess the risks of material misstatement at the financial statement.

The guidance notes that smaller or less complex entities may have ownership structures or operate in segments of the market such that the users of their financial statements may be less sensitive to misstatements than for some other entities.

And audit documentation associated with the accounting system is also likely to be relatively simple, focusing on how the main transaction cycles operate and highlighting the risks of material misstatement that arise from the nature of the systems in place.

Collings says that, where the risk of material misstatement is lower, he would be comfortable scaling back his audit approach – even relying on tests of controls to reduce substantive procedures.

“There is little to be achieved in over-auditing something where the risk of material misstatement is considered low, but I’d always try and justify my approach within the audit plan so it’s clear which angle I am coming from,” Collings says.

What’s coming next

Overall, Collings says the draft Practice Note is a good “starting point”.

“It could benefit from some more detailed guidance on scalability – especially as the FRC has indicated this is one of the concerns they have and why auditing has become more costly and off-putting to many smaller practitioners,” he says.

The consultation, which is part of the FRC’s year-long SME campaign, closes on 17 October 2025. You can read the draft Practice Note on the FRC’s site here.

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The future of accounting: 11 big shifts on the horizon

From AI agents to advisory roles, carbon accounting to cybercrime, AAT accountants and bookkeepers predict how the industry will change in the next few years.

1. Accountants will have their own AI assistants

AI is already replacing routine accounting tasks such as categorising expenses or generating invoices. Earlier this year, OpenAI (owners of ChatGPT) founder Sam Altman predicted AI agents could join workforces as “virtual employees”, while Microsoft recently forecast every organisation could become a “frontier firm” within five years, whereby human workers direct AI agents.

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Why the future’s here already

PwC has given 200,000 employees their own chatbot PA, ChatPwC.

What the accountants say

“I’m excited by the way technology frees us to focus on the human side of the job. The number-crunching is still as important as ever, but automation means we can spend more time interpreting data, advising clients and supporting them to reach their goals.” – Libby Walklett, The Ethical Bookkeeper

“AI is already helping us tailor information to users, creating a better customer experience. We can turn reports into podcasts, or summarise data with NotebookLM, so customers don’t have to read boring 20-page reports. It can even create songs should the customer want it!” – Zoe Whitman, co-founder, The 6 Figure Bookkeeper

Accountants regard AI as an enabler. AAT’s research found that, among professionals who currently work, or have previously worked, in accountancy, 42% say AI tools have been genuinely useful in their roles. Among 25–34-year-olds this figure climbs to 55%.

2. Accountants will become like “GPs for organisations”

As compliance tasks and financial reporting becomes increasingly automated, accountants will focus more on advice and business problem-solving.

Why the future’s here already

Advisory services now comprise 32% of UK practice revenue, more than bookkeeping (31%) according to Xero’s 2025 Accounting and Bookkeeping Industry Report.

What the accountants say

“I see accountants as being the ‘GPs’ of an organisation. Clients won’t just want cash flow projections; they’ll want advice on IT, suppliers and wider issues. Once people would dread calls from their accountant because it’d usually involve a scary conversation about overdue taxes. That won’t be the case anymore.” – Antoniya Beyriyska, practice manager, Ask The Boss

“Communication skills will be crucial. This is an industry where many people say ‘I’m an introvert – that’s why I love being an accountant’. Unfortunately, this isn’t what the job will be about.” – Zoe Whitman

“We don’t have old-school bank managers anymore. Accountants/bookkeepers can fill that gap, connecting business owners with other people in the local area or networks.” – Jo Wood, co-founder, The 6 Figure Bookkeeper

“We need to become business geeks, not accountants.” – Chris Argent, Founder, Generation CFO

AAT’s research finds this is a common perspective. Four in five accountants agree that automation will free them up from administrative burdens (78%), enabling them to support businesses with strategic advice and problem-solving (80%).

3. Accountants will advise on apps, HR and social media

Practices of the future will broaden their services in areas beyond finance.

Why the future’s here already

In Australia, 38% of practices now offer HR advisory, 35% app/software setup and 33% startup mentoring, according to a Xero study.

What the accountants say

“At FieCo, we assess businesses’ return on marketing and its impact on profit and loss. This helps them decide how much they should spend on marketing. Today, small companies want advisers who can connect the dots, not big-money marketing agencies.” – Ellis Harris-Boulter, Founder/Director, FieCo Accountancy

4. AI will create thousands of jobs

Yes, really. AI could create an extra 20,000 accounting jobs in the UK, which would add £2bn to the British economy according to Sage/Demos research done last year. Demand is also increasing for forensic accountants due to the rise in financial fraud and cybercrime.

Why the future’s already here

EY, Deloitte and PwC are reportedly planning AI assurance services to audit AI products, tools and systems such as self-driving cars and cancer-detecting programmes.

What the accountants say

“New roles are emerging in AI businesses, such as testing, analysis and fact-checking. Eventually, this will trickle down into accountancy – every firm could have an ‘AI integrator’” – Jo Wood

“Whenever new tech arrives, people predict the end of accountants: just think of when calculators replaced the ledger, or when cloud software came along. Accountants will always be needed because customers still want someone to interpret the numbers. Accountants’ jobs may have evolved over the years, but they haven’t disappeared.” – Antoniya Beyriyska

5. But its impact on entry-level jobs is unknown

Because AI can perform many entry-level tasks such as recording invoice or bank reconciliation, there’s a fear companies won’t know how to train beginners effectively, threatening the pipeline of future accountants.

Why the future’s already here

Jennifer Kosar, AI Assurance Leader, PwC US, told Business Insider the company is training junior employees to be able to review and supervise work done by AI, evolving the job to encompass more managerial and advisory skills.

What the accountants say

“I think AI could cause a massive skills shortage in 10-15 years’ time. If entry-level roles disappear, I worry we won’t have trained, experienced accountants by 2035.” Ellis Harris-Boulter

Fortunately, AAT’s research found that one in five accountants who have left the profession say they would return if automation could remove the more administrative aspects of the job.

6. Sustainability will create new accounting roles

With companies facing rising pressure from governments and customers to reveal their impact on nature, accountants will play a central role in ESG reporting, carbon accounting and working on 2030 net-zero transition plans.

Why the future’s already here

In February, the Financial Times reported a rise in demand for UK sustainability consultancy work, thanks to recent regulatory change. Meanwhile, the net-zero sector is growing three times faster than the overall UK economy. Today it employs nearly one million people, according to the CBI.

What the accountants say

“At the moment, publicly listed companies must report on their environmental impact. I don’t think it’ll be very long until we see smaller businesses volunteering to do the same, before it becomes legislation… At FieCo we’re planning to introduce carbon assessment and monitoring as standard in all our plans.” – Ellis Harris-Boulter

“Sustainability is something all small businesses will need to implement, whether they like it or not. If you want to be a trusted adviser, you need to set a good example. However, it’s difficult. As tech-reliant companies, we depend on software which has a massive carbon footprint. Even entering the word ‘please’ into ChatGPT consumes a lot of energy.” – Antoniya Beyriyska

7. Accountants will become more vigilant about cybercrime

As custodians of financial data, accountants are prime targets for fraudsters using deepfakes and phishing.

Why the future’s already here

 Last year a Hong Kong-based finance clerk was tricked into sending £20 million of her company’s money to fraudsters who posed as her CFO in a deepfaked video call.

What the accountants say

“Many accountants don’t understand how easy it is to be hacked – a cybercriminal could be monitoring your emails and farming your data for two years without you even knowing. As accountants, maybe we need to become cybersecurity experts to protect clients’ data.” – Ellis Harris-Boulter

8. Making Tax Digital will encourage change

The government’s long-promised digital tax system will soon be mandatory for many businesses.

Why the future’s already here

From April 2026, businesses and landlords with a turnover over £50,000 will need to use Making Tax Digital for income tax (MTD for IT).

What the accountants say

“Businesses resisting MTD are at risk. They’re more likely to click on a phishing link, for example. Accountants have a role in financially educating clients who aren’t tech-savvy.” – Zoe Whitman

9. Businesses will harness the skills of Gen Z

Gen Z are digital natives, but employers have concerns over their soft skills. Accountancy firm Forvis Mazars recently launched a learning and development programme for young employees which included lessons in “picking up the phone”.

Why the future’s already here

Well, Gen Z are the future. They’re also ambitious: 75% of UK accounting students want to run their own business according to Intuit.

What the accountants say

“There’s a reputation gap – many employers seem to think we’re lazy or workshy. But Gen Z bring an entire set of impressive digital skills. For example, most Gen Z-ers know how to use [graphic design software] Canva. They could bring skills such as graphic design into your business without even thinking about it. If organisations tapped into this, they’d become much more efficient. The way to unlock this? Listen to us.” – Ellis Harris-Boulter

10. Accountants with data analysis skills will thrive

Today, many C-suites expect accountants to integrate non-financial data such as sales funnels, customer behaviour, supply chain performance and ESG metrics to provide a more complete picture of organisational health.

Why the future’s already here

AAT offers several data analysis courses: Data Analysis for Accountants, including Career Progression Pathway: Finance Data Analysis.

What the accountants say

“The skill isn’t just data analysis – AI can do that now. It’s knowing what you want to achieve with that data analysis.” – Zoe Whitman

“Data analysis will help us use big data for small clients. It will help practices have an edge and be competitive.” – Ellis Harris-Boulter

11. So will practices marketing themselves like influencers

As the New York Times recently noted, “Businesses where intelligence and expertise are the differentiating traits will have to pivot. Take financial-services firms, for example… how do they stand out from one another? The answer may be found in ‘taste’ roles – how they communicate and market themselves, how they show up to customers, their creative philosophies.”

Why the future’s here already

Just look at the many successful young accounting influencers who also run successful businesses: Rachel Harris (StriveX; 150,000 Instagram followers), Grace Hardy (25,000 LinkedIn followers).

What the accountants say

“In an age of TikTok and the personal brand, influencer marketing – whether you like it or not – is what people are looking for. When customers see a human they can trust, they’re confident they’re making the right decision. Bookkeeping and accountancy practices will need to make sure they have key people of influence out there building a personal brand and trust with customers.” – Zoe Whitman

AAT Connect is back

Join us on Friday 7 November to stay ahead of the curve on industry trends.

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Suspicious Activity Report best practice videos

Here are clear instructions to help you handle difficult issues.

A Suspicious Activity Report (SAR) alerts law enforcement that certain client activity or transactions are in some way suspicious and might indicate money laundering or terrorist financing activity. It provides valuable information on potential criminality and protects you, your organisation and UK financial institutions from the risk of laundering the proceeds of crime. 

Given the importance of SARs, we strongly encourage you to watch these six short Best Practice Videos produced by the UK Financial Intelligence Unit (UKFIU) covering the following topics:

  1. What is a SAR and why do I need to submit one?
  2. Know your Glossary Codes
  3. Reason for Suspicion
  4. Best practice for completing the criminal / terrorist property section
  5. Best practice for completing the prohibited act section
  6. What happens after you submit a DAML or DATF?

Further guidance and support on MLR compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email [email protected].

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