For years, the regulatory landscape for professional services has been divided. Law firms have navigated the rigorous, often prescriptive world of the Solicitors Regulation Authority (SRA), while accountants have operated under a patchwork of professional bodies like the ICAEW, ACCA, and HMRC.
However, the tide is turning. With the Financial Conduct Authority (FCA) set to assume a more dominant role as the Single Professional Services Supervisor, accountants are facing a regulatory “leveling up” that brings their oversight closer to, and in some ways, more intense than, that of law firms.
For practices looking to survive this transition, the Accountancy AML Checklist is no longer just a helpful tool; it is a fundamental requirement for regulatory survival.
Law vs. Accountancy: The Changing Face of AML Supervision
Historically, the SRA has been viewed as a more “hands-on” regulator compared to the diverse supervisors in the accountancy sector. Law firms, certainly in the last five years, have become accustomed to granular AML audits and strict transparency requirements.
In contrast, many UK accountancy firms have historically relied on “check-box” compliance. That era is about to end. As the FCA moves into the role of overseeing the accountancy sector, the expectations for a robust Accountancy AML Checklist are shifting from static documents to “live” risk-management frameworks.
Key Differences in Oversight:
- The SRA Approach (Law Firms): Focuses heavily on the “Outcome-Focused Regulation.” Law firms must prove not just that they have an AML policy, but that the policy resulted in a specific, compliant outcome. Files are reviewed as part of a SRA AML audit.
- The FCA/CCAB Approach (Accountants): Traditionally more guidance-based, but moving rapidly toward a data-heavy, prescriptive model. The FCA expects accountants to provide an evidence trail that rivals the most scrutinised law firms.
Why the “Accountancy AML Checklist” is the Center of the 2026 Transition
The core of this regulatory shift is the move away from generic templates. Under the new 2026 standards, using a “one-size-fits-all” Accountancy AML Checklist is considered a major red flag by regulators.
Whether you are a high-street generalist or a boutique firm specialising in Trust and Company Service Provider (TCSP) work, your checklist must be a “live” reflection of your firm’s specific DNA.
1. Risk-Based DNA
An effective Accountancy AML Checklist must differentiate between service lines. For example, the risk profile of a simple payroll client is vastly different from a client involved in international corporate restructuring. If your checklist treats them the same, you are failing the “risk-based approach” mandated by the CCAB and the FCA.
2. Proliferation Financing & Companies House Changes
The 2026 landscape introduces new complexities, such as mandatory checks for proliferation financing and updated Companies House ID verification rules. A manual or outdated Accountancy AML Checklist likely misses these granular requirements, leaving the Money Laundering Reporting Officer (MLRO) personally exposed.
The “Double Jeopardy” for Modern Accountants
Accountants currently find themselves in a period of “double jeopardy.” They must satisfy the legacy requirements of their current professional body (ICAEW/ACCA/HMRC) while simultaneously “audit-proofing” their files for the incoming FCA regime.
This is where many firms fall behind. Law firms have had years to adjust to the SRA’s rigorous reporting; accountants are being asked to bridge that gap in a much shorter timeframe. Utilising a dynamic Accountancy AML Checklist is the only way to ensure that your Whole-Firm Risk Assessment (WFRA) and Policies, Controls, and Procedures (PCPs) are defensible under both current and future oversight.
Moving Beyond AML Templates
The most significant takeaway for firms today is that a downloadable, static PDF is no longer sufficient. Regulators now view generic, unedited PCPs as evidence of a failure to apply a risk-based approach.
To truly protect your Practicing Certificate, your Accountancy AML Checklist must be:
- Dynamic: Updated in real-time as CCAB guidance evolves.
- Evidence-Backed: It must point directly to the “ongoing monitoring” of long-term clients.
- Bespoke: Tailored to your firm’s specific jurisdictional exposure and client types.
Conclusion: Prepare for the FCA Era
As the FCA prepares to take the lead, the gap between law firm oversight and accountancy oversight is closing. The firms that thrive will be those that treat their Accountancy AML Checklist as a core pillar of their business strategy rather than a yearly administrative burden.
Don’t wait for a monitoring visit to discover your gaps. The transition to the 2026 standards is already underway—ensure your firm is ready for the oversight shift today.
For accountancy firms looking to bridge the gap between their current procedures and the 2026 FCA standards, AML-Checklist.com offers expert-led consultations to turn your static checklist into a robust, defensible framework.