Anti-Money Laundering CPD for Accountants — 2026 Compliance Guide
AML CPD is a compliance requirement for accountants in money laundering-regulated firms. This guide covers AML training requirements, what counts, and how HMRC enforces compliance in 2026.
Anti-money laundering (AML) training is a legal requirement — not just a professional development option — for accountants working in firms that fall under the Money Laundering Regulations 2017. If your firm provides accountancy, audit, tax advisory, or trust and company services, AML compliance training is mandatory under UK law.
Who Needs AML Training?
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) require firms in scope — including accountancy practices — to train their staff on AML obligations. This applies to partners, directors, managers, and any staff involved in transactions or client relationship management that could give rise to money laundering risk. Supervisory bodies including ICAEW, ACCA, CIMA, AAT, and HMRC oversee compliance in the accountancy sector.
What AML Training Must Cover
AML training for accountants must cover: what money laundering is and how it occurs; the three stages of money laundering (placement, layering, integration); suspicious activity indicators relevant to the accountancy sector; the obligation to submit Suspicious Activity Reports (SARs) to the National Crime Agency (NCA); customer due diligence (CDD) and enhanced due diligence (EDD) procedures; Politically Exposed Persons (PEPs) and sanctions screening; and tipping-off and confidentiality restrictions. Training must be tailored to the firm's specific risk profile — generic awareness training alone is unlikely to meet the MLR requirements for firms with complex client portfolios.
How Often Should AML CPD Be Completed?
The MLRs require training to be provided on a regular basis and updated when requirements change. Most supervisory bodies recommend AML training be repeated at least annually, or whenever there are significant changes to the AML regime (new guidance, updated FATF recommendations, or changes to the sanctions regime). One-off training at induction is not sufficient for ongoing compliance.
HMRC Enforcement of AML Compliance
HMRC acts as a supervisory authority for accountancy service providers not supervised by a professional body. HMRC can carry out inspections and take enforcement action against firms that fail to comply with the MLRs. HMRC can issue civil penalties for non-compliance — the level of any penalty is determined on a case-by-case basis, taking into account the firm's size, the severity of the breach, and the degree of culpability. There is no fixed statutory maximum penalty per breach; penalties are calculated to reflect the circumstances of each case.
AML CPD and Professional Body Requirements
ACCA, ICAEW, CIMA, and AAT all require their members to maintain AML competence as part of their CPD obligations. AML training completed through an approved provider counts toward the verifiable CPD requirement. Professional bodies also conduct AML monitoring visits to practices — evidence of current AML training is expected during these visits.
Frequently Asked Questions
Does my firm need AML training if we are supervised by ICAEW rather than HMRC? Yes. All firms in scope of the MLRs must provide AML training regardless of their supervisor. The supervising body's expectations may differ in emphasis but the MLR training obligation is the same.
What records should we keep of AML training? Keep records of who was trained, what the training covered, when it was completed, and the provider. These records should be retained and made available to your supervisor on request.
Further Reading
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