Sector assessment
8 laundering methods apply to this sector. 5 are rarely covered in standard AML training. The sector assessment uses 5 cases.
Accountants produce the record other institutions rely on, including the accounts that make an implausible business look filed and settled.
Client take-on tests identity and rarely tests economic sense. A set of accounts that reconciles is treated as a set of accounts that is true, and the practice's own client account attracts less scrutiny than a bank would give the same flows.
HMRC supervises the largest share of the sector, with the professional bodies supervising the rest, and the Insolvency Service pursues directors separately. Elphysic Ltd v HMRC [2025] UKUT 236 (TCC) confirmed that a nominal director is a design feature of the scheme rather than a defence to it.
Anyone providing accountancy, audit, tax advice or insolvency services by way of business is a relevant person, whether supervised by a professional body or by HMRC directly. Providing a registered office or acting as a formation agent is separately in scope as a trust or company service provider, and a practice doing it as a sideline is doing it as a relevant person.
Not one case. Every case that exercises a typology on your list is part of your mark, weighted by how much of your exposure it carries. The weights are derived from the register rather than chosen, so adding a case re-derives them instead of leaving the old ones wrong.
| Case | Your typologies | Share of your mark |
|---|---|---|
| The Client Engagementwritten for your desk | 6 | 46% |
| The Client Account | 3 | 23% |
| The Relationship Review | 2 | 15% |
| The Fundraising Appeal | 1 | 8% |
| The Onboarding Interview | 1 | 8% |
£99one payment, 12 months, nothing renews
£750pilot, up to 25 people, invoiced
Drawn from the full register and filtered to this sector. Each entry states what the typology looks like inside your own systems, and names the source it came from. 8 of the 8 are currently exercised by an assessment case; the rest are documented here and not yet built into one.
A company is dissolved or struck off the register yet continues to bank, invoice and transact, because registry status is checked at onboarding and never again.
An established account whose entity no longer exists at the registry. Detectable only by re-verifying incorporation status across the existing book, which is a batch job most firms have never run.
A regulated professional's client account is used as a banking facility, lending the transaction the firm's own reputational cover and obscuring the underlying parties.
Client account movements with no underlying legal or accountancy transaction, funds returned to source shortly after receipt, and pooled balances that cannot be reconciled to matters.
Company formation, nominee director, registered office and trustee services are supplied at scale, assembling the structures other typologies depend on.
Clusters of customers sharing a registered office, a formation agent or a nominee, incorporated in batches, and presenting near-identical onboarding documentation.
Books and records are falsified to give criminal funds a documented commercial origin, and a professional accountant is then engaged to prepare financial statements from them. The resulting accounts carry the adviser's standing rather than the client's, and are what a bank, a lender or a registry subsequently relies on.
Filed accounts showing turnover a business of that size, premises or headcount could not generate; certificates of confirmation supporting figures no independent record corroborates; and a cash-intensive client whose declared takings rise without any matching change in the operation.
Value is extracted from a company before it is wound up, and the liquidation then terminates scrutiny: the trade continues through a successor while the debts and the records stay with the entity that failed. The wind-up presents as ordinary commercial failure, which is the point.
Assets and trade transferred to a newly incorporated company with the same operation and different directors shortly before insolvency; directors with a history of successive failed companies in the same trade; and a company whose final months show payments to connected parties rather than to creditors.
A charitable structure is created or captured to provide a legitimate-looking channel for funds, exploiting the sector's donation-based inflows and disbursement to high-risk jurisdictions.
Donation inflows inconsistent with any visible fundraising activity, grant disbursements to unverifiable overseas partners, trustee turnover with no succession, and cash withdrawals in conflict-adjacent jurisdictions.
Criminal funds are placed offshore and then lent back to the launderer, so the money returns as borrowing, complete with a repayment schedule, an interest deduction and an apparently arm's-length lender.
Borrowing from an offshore entity with no lending business, security or guarantees provided by parties connected to the borrower, interest paid to a jurisdiction unrelated to the transaction, and loans that are never enforced when they fall into arrears.
A workforce is fragmented across hundreds or thousands of small companies so each can claim employment allowances and VAT thresholds it is not entitled to, with companies replaced on a rolling basis before scrutiny arrives.
Large numbers of newly incorporated companies sharing directors, addresses or formation agents, each running modest payroll, appearing and dissolving on a cycle.
The Client Engagement carries 6 of the 8 typologies above and 46 per cent of your mark. Full debrief, no account, no card.
Start The Client EngagementRun the full Accountancy benchmark across up to 25 people for £750.
No integration · No customer data · Confidential cohort available
One documented case each week. One decision. The answer and the source afterwards.
