Policies for Accountants and Professional Services Firms

This page is for accountancy practices, bookkeepers, tax advisers, payroll bureaus and adjacent professional services firms that need their compliance documents written properly. Policy Pros writes bespoke policies and procedures around your actual practice, from the firm-wide risk assessment your AML supervisor expects to the staff handbook your team uses every day.

Bespoke, audit-ready policies from £65 + VAT per document. Get a quote or call 020 3951 2875 for a free scoping conversation.

Policies Accountants and Professional Services Firms Need

Legally Required

• Firm-Wide AML Risk Assessment - required by regulation 18 of the Money Laundering Regulations 2017, with a written record kept up to date
• AML Policies, Controls and Procedures - required by regulation 19 of the Money Laundering Regulations 2017 and must be approved by senior management
• Client Due Diligence Procedure - regulations 27 and 28 of the Money Laundering Regulations 2017 require identity checks before you act for a client
• AML Record-Keeping Procedure - regulation 40 of the Money Laundering Regulations 2017 requires due diligence records to be kept for five years
• Nominated Officer and Internal Reporting Procedure - regulation 21 of the Money Laundering Regulations 2017 and the Proceeds of Crime Act 2002 (suspicious activity reports to the National Crime Agency)
• AML Staff Training Programme - regulation 24 of the Money Laundering Regulations 2017 requires relevant employees to be trained, with records kept
• Data Protection Policy - UK GDPR and the Data Protection Act 2018 apply to every client record you hold
• Health and Safety Policy Statement - Health and Safety at Work etc. Act 1974, a written statement is required once you have five or more employees

Expected by Regulators and Clients

• Anti-Tax Evasion Policy - reasonable prevention procedures are the only defence to the Criminal Finances Act 2017 facilitation offences
• Fraud Prevention Procedures - the failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act 2023 applies to large organisations, and clients increasingly ask smaller firms for the same controls
• Clients' Money Procedure - the ICAEW Clients' Money Regulations and equivalent ACCA rules apply where you hold client funds
• Whistleblowing Policy - expected by professional bodies and by clients running supplier due diligence
• Ethics and Conflicts of Interest Policy - the ICAEW and ACCA codes of ethics require documented safeguards against conflicts
• Sanctions Compliance Policy - supervisors expect screening procedures under the UK financial sanctions regime

Who Supervises Your Firm for Money Laundering

Every accountancy service provider must be supervised for anti-money laundering purposes before trading. Firms regulated by ICAEW, ACCA or another professional body are supervised by that body, while everyone else, including many independent bookkeepers and tax advisers, must register with HMRC as the default supervisor.

The government has confirmed that the Financial Conduct Authority will eventually take over AML supervision of professional services firms. The transfer needs primary legislation and is some years away, but the direction of travel is towards closer scrutiny, and supervisors are already tightening their monitoring. Our AML policy writing service covers the full document set.

What Monitoring Visits Look For

Professional body monitoring reviews and HMRC compliance checks start with the paperwork. Reviewers ask for the firm-wide risk assessment, the written policies, controls and procedures, sample client due diligence files and training records, and a missing or out-of-date risk assessment is one of the most common findings.

ICAEW Practice Assurance reviews also test how firms handle client money, engagement letters and complaints. Clients' money compliance was the most common findings area in ICAEW's 2026 Practice Assurance monitoring report.

Alongside the AML set, reviewers expect sensible internal financial controls covering authorisation, payments and expenses. Our finance policies and procedures service covers these documents for practices of any size.

The Economic Crime Levy

Firms supervised under the Money Laundering Regulations with UK revenue above £10.2 million pay the annual economic crime levy, which HMRC collects from accountancy firms. The bands were restructured from April 2026, starting at £10,200 a year for firms in Band A.

Most small practices sit below the threshold and pay nothing. The exemption from payment does not reduce any of the documentation duties above.

Fraud and Client Data

Accountants sit close to client money and client records, so fraud and data duties bite harder here than in most sectors. The failure to prevent fraud offence has been in force since 1 September 2025, and our employer guide to the offence explains who is caught and what reasonable procedures look like.

Client records are personal data under UK GDPR, which means a data protection policy, retention rules and breach procedures. Staff-facing documents matter too, and our HR policies and procedures service covers contracts, handbooks and disciplinary procedures for practice teams.

What Policy Pros Delivers

• Bespoke documents written around your actual practice, client base and risk profile, not a generic template
• A fixed-price quote before any work starts
• Review rounds included, so you can adjust wording before sign-off
• Final documents supplied on professionally branded templates, ready to show a reviewer

If you already have policies that need bringing up to date, our policy document reviewing service checks them against current requirements.

Extremely professional and thorough. The policies were tailored perfectly to our sector and delivered ahead of schedule.

Policy Pros is rated by verified clients on Trustpilot.

How to Get Started

Tell us about your practice, your supervisory body and any monitoring visit or deadline you are working to. We will scope the documents you actually need and send a fixed-price quote with no obligation. Get a quote or call 020 3951 2875.