Anti-Money laundering overview and registration

18 Nov 2021

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. 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 

Please apply for supervision with CIOT/ATT before you start trading or as soon as possible afterwards. There are implications where members do not register promptly (see below).  

We will need you to email aml@tax.org.uk with the following information in order to set your firm up on our system:   

  • Name of CIOT member 
  • Membership number 
  • Confirmation of email address 
  • Name of business 
  • Date business commenced trading or intends to commence trading 
  • Type of entity being registered, i.e. sole practice, limited company, partnership or LLP 
  • Membership details of other supervisory professional bodies for all principals in the business (principal means a sole practitioner, 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 the principals, office holders and any manager with responsibility for AML within the firm. See criminality checks paragraph below for further detail.

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 CIOT 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 seelate registration policyand guidance note for further detail.

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.