Professional Enablers: What Accountants Need to Know

"Professional enabler" is a term accountants will hear more often. It describes an individual or organisation providing professional services that enable criminality, and the UK now has a cross-government strategy aimed at them. Accountancy is named as one of the sectors affected. This guide explains what the strategy says, what it deliberately does not say, and what an accountancy firm can sensibly do about it. It draws on the Cross-System Professional Enablers Strategy and the National Crime Agency (NCA) UK Financial Intelligence Unit's "SARs in Action" bulletin for September 2024, and it is general information, not legal advice.

What the strategy defines as a professional enabler

According to the strategy, developed by the National Economic Crime Centre (NECC) and the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) with government, supervisors, law enforcement, prosecutors and the private sector, a professional enabler is an individual or organisation providing professional services that enable criminality. The strategy says the conduct may be deliberate, reckless, improper, dishonest or negligent, through a failure to meet professional and regulatory duties. That last point matters for firms. The definition is not limited to people who knowingly help criminals, and it includes failing to meet your own obligations.

The strategy describes financial and professional services as gatekeepers. It acknowledges that most firms invest heavily in preventing misuse, and says a minority can damage the reputation of their sector and of the UK as a financial centre. It lists the sectors that professional enablers can affect as banks, money service businesses, estate agents, trust or company service providers, art market participants, the legal sector and accountancy.

Six objectives and six pillars

The strategy covers 2024 to 2026 and is a commitment under the second Economic Crime Plan, published in 2023. It sets out six objectives: build a sector-level understanding of the threat, ensure quality information sharing between law enforcement and supervisors, strengthen and coordinate capabilities across the system, prevent enabling activity through supervision, achieve lasting disruptive impact, and become a world leader in responding to professional enablers. These are organised under six pillars: threat understanding, information and intelligence sharing, system coordination, protecting financial and professional services, impactful disruptions, and international response.

The strategy says disruption will use the full range of civil and criminal powers together with supervisory interventions, and that prosecutors will be involved early in case strategy. Its partners include the NECC, OPBAS, the NCA, HM Revenue and Customs, the Financial Conduct Authority, the accountancy and legal professional body supervisors, the Crown Prosecution Service and Companies House.

What the strategy does not say

It is worth being clear about the limits. The strategy is a high-level document. In the version we reviewed it does not set out accountancy-specific obligations, red flags or typologies, and it does not give specific compliance steps for firms. It says the response is to build understanding of economic crime risks and support supervision that stops enablers operating. Firms should therefore treat it as a statement of direction rather than a rulebook, and look to the Money Laundering Regulations, supervisor guidance and sector risk assessments for what they must actually do. HMRC's sector risk assessment already lists professional enablers among the risk factors for accountancy service providers, as we explain in our guide to AMLG3700.

What has happened since

OPBAS's 2024/25 report says it leads actions under the strategy, including reports on common breaches and suspicious activity reports, a project on barriers to information sharing, intelligence-handling training and presentations to supervisors. It says the strategy's remit ended in April 2026 and that OPBAS is discussing next steps with the NECC. Our summary of that report is in our guide to the OPBAS 2024/25 report. Until a successor is announced, the practical direction is clear: supervisors are expected to share intelligence with law enforcement and to act earlier on weak firms.

One concrete typology: virtual squatting

The NCA bulletin gives one example relevant to accountants. It describes "virtual squatting", where criminals register the addresses of serviced offices, accountants and law firms with no agreement or contract in place, to create false legitimacy or evade investigation. It reports that a cell had identified 77 instances, and that Companies House dissolved 22 firms, added 20 to its default address register, and identified 10 squatters no longer using their registered addresses. The bulletin refers to an NCA Amber Alert on the typology and explains how to flag related reports on the SAR Portal. Alert references and glossary codes change, so check the current list before you report rather than relying on an older bulletin. Our guide to the MLRO's role covers how an internal concern becomes a report.

Practical steps for accountancy firms

These are our suggestions, not requirements in the strategy:

• Check where your address is used. If your office address is used by clients, ask whether you have a written agreement for each, and what you do if post arrives for a company you do not act for.
• Treat negligence as a risk. Because the definition includes failing to meet professional duties, missed due diligence or unreviewed alerts are your exposure too.
• Keep escalation simple. Staff should know who to tell if a client or an introducer seems to be asking the firm to lend credibility to something it cannot verify.
• Look at introducers and referral chains. Where a client arrives through another professional, record how you tested the relationship and whether the introduction fits what you know.
• Link it to your risk assessment. Our guide to the firm-wide risk assessment covers where this risk belongs.

Frequently asked questions

Does the strategy create new legal duties for accountants?

Not in the version we reviewed. It describes a cross-government approach and does not set out specific compliance steps for firms. Your duties come from the Money Laundering Regulations and your supervisor's rules.

Can a firm be a professional enabler without meaning to be?

The strategy's definition includes conduct that is reckless or negligent through failure to meet professional and regulatory duties, so intent is not the only test.

Is the strategy still in force?

It covered 2024 to 2026, and OPBAS says its remit ended in April 2026, with next steps under discussion. Check supervisor announcements for any successor.