Nepal AML Obligations for Accountants: The Asset (Money) Laundering Prevention Act and FIU-Nepal
What FIU-Nepal's guidelines say about AML duties for auditors and accountants under the Asset (Money) Laundering Prevention Act, and what we could not confirm.
In Nepal, auditors and accountants are listed as reporting entities under the Asset (Money) Laundering Prevention Act, 2008 (ALPA), which is enforced through the Financial Information Unit of Nepal (FIU-Nepal) inside Nepal Rastra Bank. This guide sets out what the FIU's own published guidelines say about the duties that reach accountants, and what we could not confirm. It is general information, not legal advice.
Who is covered
FIU-Nepal's suspicious transaction reporting guidelines, updated in July 2021 and issued under section 10(1)(h) of the ALPA, list the reporting entities. Alongside banks, insurers and cooperatives, the designated non-financial businesses and professions include real estate businesses and agents, trust and company service providers, casinos, dealers in precious stones and metals, notary publics, law practitioners, and auditors and accountants. A separate FIU list of "other" reporting entities names the Institute of Chartered Accountants of Nepal (ICAN) as the regulator for auditors and accountants.
The FIU's website also lists the amended Act (an amendment dated 2080 in the Nepali calendar, published on the site in April 2024), the Asset (Money) Laundering Prevention Rules, 2081 (published November 2024) and a first amendment to those Rules (published January 2026). We could not read the Nepali-language texts, so this guide relies on the FIU's English-language guidelines.
Reporting suspicious transactions
According to the FIU's guidelines, section 7S(1) of the ALPA requires a suspicious transaction report (STR) to the FIU "within three days as far as possible". The guidelines add that reports should be made as soon as practicable and no later than three working days after grounds for suspicion are established. Attempted transactions must be reported as well (section 7S(2)), and there is no monetary threshold for suspicious transaction reports. The guidelines say customer due diligence, and enhanced due diligence in high-risk cases, should be completed and updated before reporting.
The guidelines say that banks, insurers, securities brokers and other assigned reporting entities file electronically through the goAML system, while other reporting entities file signed paper reports, with the rollout phased by group. We did not find a statement of which route applies to accountants, so ask the FIU. For the practical sequence of spotting, escalating and reporting a suspicion, see our guide to suspicious activity reports and tipping off, which is UK-focused but explains the steps.
Compliance officer
Under section 7P of the ALPA, as the FIU's guidelines describe it, each reporting entity must appoint a compliance officer at management level to file reports and deal with the FIU, and should have clear internal reporting procedures. A small practice has to decide who holds that role. Our guide to KYC and customer due diligence in accountancy practices covers the general method for the checks that feed reporting.
Threshold transaction reports
FIU-Nepal's threshold transaction reporting guidelines (version 3, July 2025) rely on section 10A of the ALPA and Rule 35 of the 2024 Rules. They require reports of transactions above sector thresholds within 15 days. For auditors and accountants regulated by ICAN, the guidelines list them as reporting entities but set no threshold in their table, and say the threshold transaction provisions have not been mentioned in the relevant directives. Notary publics and law practitioners are in the same position. So as of that guideline, we found no stated threshold for accountants, but the guideline says thresholds can change by notice from Nepal Rastra Bank, so check the current position.
Tipping off and penalties
Section 44A(1) of the ALPA, as the FIU's guidelines summarise it, bars reporting entities, their officials and staff from telling customers or others that a report has been or is being made. Under section 44A(4), the regulator may fine up to Rs 1,000,000 for each violation by banks, financial institutions or casinos, and up to Rs 200,000 for other designated non-financial businesses and professions. Under section 10(7), the FIU may fine a reporting entity up to Rs 1,000,000, depending on the gravity of the case, for failing to submit a suspicious transaction report, failing to comply with prescribed conditions, or failing to submit documents it has ordered.
What we could not confirm
- The full text of the amended ALPA and the 2081 Rules, including the customer due diligence and record-keeping provisions, because they are in Nepali.
- Whether ICAN has issued an AML directive for auditors and accountants. The FIU's list of directives does not show one.
- Which activities by an accountant trigger the obligations, and whether the duties apply to every audit or accounting firm.
- The record-keeping period. The suspicious transaction guidelines do not address it.
Suggested next steps
These are our suggestions, not requirements. Ask ICAN or the FIU in writing whether your firm must register on goAML, and which obligations apply to your services. Name a compliance officer and write down how staff escalate a suspicion. Compare the approach with a neighbouring regime, such as India's PMLA obligations for chartered accountants. For team training, see our CPD courses.
Frequently asked questions
Are accountants in Nepal covered by AML law?
According to FIU-Nepal's guidelines, auditors and accountants are listed reporting entities under the ALPA, and ICAN is named as their regulator.
How quickly must a suspicion be reported?
Within three days as far as possible under section 7S(1), and no later than three working days after grounds for suspicion are established, according to the FIU's guidelines.
Is there a cash reporting threshold for accountants?
The FIU's July 2025 threshold guidelines list accountants as reporting entities but set no threshold for them. Check for later notices.
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