UK National Risk Assessment 2025: What It Says About Accountants and TCSPs
The UK's fourth National Risk Assessment, published in July 2025, kept accountancy at high money laundering risk and raised TCSP terrorist financing risk to medium. Here is what to do about it.
The UK's national risk assessment (NRA) of money laundering and terrorist financing is the government's official view of where the risks sit. The fourth edition, published by the Home Office and HM Treasury on 17 July 2025, matters directly to accountants because anti-money laundering (AML) supervisors expect firms to use it when they assess their own risks. This guide sets out what the NRA says about accountancy service providers (ASPs) and trust and company service providers (TCSPs), based on the AAT's published summary, and how to turn it into action. The AAT article is a secondary source, so read the full NRA on GOV.UK for the exact wording.
The headline ratings
| Sector | Money laundering risk (2020 to 2025) | Terrorist financing risk (2020 to 2025) |
|---|---|---|
| Accountancy service providers | High to High (no change) | Low to Low (no change) |
| Trust and company service providers | High to High (no change) | Low to Medium (increase) |
The ICAEW also reported that money laundering remains a high risk for accountants under the latest assessment. The only rating that changed was the TCSP terrorist financing risk, which rose from low to medium.
Which services carry the most risk
According to the AAT, the NRA identifies payroll, bookkeeping, trust and company services and tax advice as the services most at risk. If your practice offers any of these, treat them as areas that need particular attention in your risk assessment. For the bookkeeping and payroll angle, see our guide to AML for bookkeepers, virtual assistants and payroll.
Vulnerabilities in the accountancy sector
The AAT lists the following vulnerabilities taken from the NRA.
- Fragmentation of services across firms.
- Non-compliance with the Money Laundering Regulations 2017, through poor knowledge, weak controls or poor customer due diligence.
- Supply-chain structures that can conceal end users.
- Clients linked to higher-risk jurisdictions or overseas PEPs.
- Cash-intensive clients.
- Tax evasion.
- Firms giving false legitimacy to front-company accounts.
Why TCSP terrorist financing risk rose
The AAT's summary lists the factors that raise this risk. They include weak identity verification, complex corporate structures, funds held in or contributing to trusts, nominee directors or shareholders, negligent or complicit TCSP behaviour, and inadequate due diligence and risk assessments. If you form companies or act as a nominee, our guide to TCSP obligations explains the duties.
New and emerging threats
The AAT says the NRA names artificial intelligence, digital platforms and cryptoassets as technologies that let criminals move and hide illicit funds. It also notes that profits from modern slavery and human trafficking are laundered through money mules and front companies, such as hairdressers or grocery stores. The NRA states there is increasing alignment between money laundering, kleptocracy and sanctions evasion, so treat sanctions screening as part of the same risk picture rather than a separate exercise. The AAT summary does not cover every theme in the full document, so check the source if a topic matters to you.
What accountants should do
The AAT's guidance, which reflects its role as a supervisor, is to take the following steps.
- Read the NRA 2025 in full.
- Update your firm-wide risk assessment. The AAT points to Regulation 18 of the Money Laundering Regulations 2017, which requires the assessment to be documented and kept up to date, and says it can ask to see yours during a Practice Assurance Review or on an ad hoc basis. Our guide to the firm-wide AML risk assessment shows how to structure it.
- Update policies, controls, procedures and customer due diligence measures to reflect the NRA's findings.
- Train staff where you have any.
- Report suspicious activity. If you know, suspect or have reasonable grounds to suspect money laundering or dealing in criminal property, submit a Suspicious Activity Report to the National Crime Agency.
A practical way to use the NRA
A simple method is to take the vulnerabilities list above and test each one against your client base and your service lines. Ask how many clients are cash-intensive, how many have overseas links or PEP connections, and which of your services involve holding or moving money. Write down what you find and what you did about it. The aim is a risk assessment that is specific to your firm, not a copy of the national one.
Frequently asked questions
When was the fourth NRA published?
On 17 July 2025, by the Home Office and HM Treasury, according to the AAT.
What is the money laundering risk rating for accountants?
High, unchanged from the 2020 assessment.
What changed for TCSPs?
The terrorist financing rating rose from low to medium. The money laundering rating stayed high.
Do I have to use the NRA?
Your supervisor expects your firm-wide risk assessment to be informed by it. Check your own supervisor's guidance for the precise expectation.
Next steps
Put a date in the diary to review your firm-wide risk assessment against the vulnerabilities above. To build your team's skills, explore Learnsignal's CPD courses.
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