Sector assessment
21 laundering methods apply to this sector. 7 are rarely covered in standard AML training. The sector assessment uses 14 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 | 8 | 19% |
| The Relationship Review | 6 | 17% |
| The Client Account | 5 | 14% |
| The Policy Book | 4 | 11% |
| The Invoice Pack | 2 | 6% |
| The Onboarding Interview | 2 | 6% |
| The Private Client File | 2 | 6% |
| The Alert Queue | 1 | 3% |
| The Fundraising Appeal | 1 | 3% |
| The Disclosure | 1 | 3% |
| The Goods Chain | 1 | 3% |
| The Incoming Payment | 1 | 3% |
| The Securities Book | 1 | 3% |
| The Sponsorship File | 1 | 3% |
£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. 21 of the 21 are currently exercised by an assessment case; the rest are documented here and not yet built into one.
A genuine cash trading business banks criminal cash alongside its own takings, using the trade's plausible cash profile as cover.
Deposit volumes far exceeding what the trade supports, physical tells at the counter, and transaction monitoring that misclassifies the deposit type.
A real trading business is used as cover, but the laundered volume bears no relationship to what the business physically does.
Merchant acquiring data, utilisation meters, headcount or occupancy flat while account credits multiply. The business has not grown; only the account has.
Deceased individuals are recorded as directors, officers and shareholders, and accounts opened by the living are run on after death. There is no accomplice who can be pressured, because the nominal principal is dead.
An account in good standing whose signatory died in a jurisdiction the firm does not search, filings continuing for a director with no verifiable life, and mandates never refreshed because the account never triggered a review.
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.
Layered holding structures across free-zone and offshore jurisdictions terminate in a corporate nominee, so the declared beneficial owner is asserted rather than evidenced.
A structure chart that never evidences control, a nominee shareholder defeating verification, and a customer who offers further documents instead of an answer.
Residence or citizenship is obtained through qualifying investment, converting funds of uncertain origin into a residency status that subsequently anchors banking relationships and asset holdings.
Source of wealth evidenced principally by the qualifying investment itself, onboarding shortly after grant of status, and jurisdiction of residence inconsistent with any economic or family connection.
Advisory, market-access and logistics consultancy invoiced in round sums with no hours, rates, deliverables or dates. Services carry no customs reference value, which is why the typology migrated from goods.
Round-figure invoices, no schedule of services, fee levels the file does not justify, and counterparties incorporated shortly before the contract date.
Invoices are raised on customers sharing a registered office, a director or ownership with the client, so the receivables being financed are the client's own money circulating.
Shared registered offices, a recently resigned common director, and invoice numbers running in unbroken sequence across supposedly unrelated customers.
Borrowing is obtained on fabricated income, undisclosed deposits of criminal origin, or inflated valuations, and the loan both launders the deposit and generates a legitimate ownership record.
Deposits gifted by parties with no evidenced means, income documentation that cannot be corroborated with the employer or HMRC, valuations materially above comparable sales, and early full repayment shortly after completion.
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.
Assets pass through the administration of a deceased person's estate, where the party whose funds they were is beyond enquiry. Due diligence is performed on executors and beneficiaries; the deceased is not checked, and the estate's assets move through a firm's client account before distribution.
Estate funds arriving from a professional's client account with no visibility of their origin; assets appearing in an estate that the deceased's known circumstances do not explain; and a firm that is itself the executor, where no external party sees the administration at all.
Improper payments are routed as consultancy fees, royalties, dividends or capital gains so the receipt reads as ordinary income.
Consultancy receipts from jurisdictions where the recipient holds influence, payments unconnected to any deliverable, and timing correlated with contract awards.
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.
Goods are traded through a chain of companies across borders. A trader collects VAT and disappears before accounting for it, while the goods may circulate repeatedly through the same chain.
Rapid high-value trading between newly incorporated counterparties in the same goods, payments that pass through in hours, margins too thin to support the businesses, and directors with no trading history in the sector.
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.
Grants, loans and relief schemes are claimed by entities created or repurposed for the claim, with proceeds extracted before any repayment obligation crystallises.
Scheme proceeds received by a company with no prior trading history, immediately dispersed to directors or connected parties, followed by dissolution.
Ownership is diluted below control thresholds or transferred to non-designated relatives and managers after designation, leaving effective control unchanged.
Ownership changes closely following a designation date, incoming owners with no commercial history, and unchanged management across the restructuring.
The Client Engagement carries 8 of the 21 typologies above and 19 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.
