ECSH52575 - Professional Body Supervision
Source: gov.uk (2025-10-27)


The 22 Professional Bodies (PBs) which act as Professional Body Supervisors (PBSs) are listed in Schedule 1 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) (https://www.legislation.gov.uk/uksi/2017/692/schedule/1).

These PBs offer affiliation and professional membership to those working in the accountancy and legal sectors. With this membership those working in accountancy related roles can demonstrate that they meet nationally or globally recognised professional and ethical standards set out by the relevant PB. This is usually done by training, passing qualifying examinations and undertaking practical work experience, before being accepted as a member. Membership attracts an annual fee, and members must adhere to codes of professional and ethical conduct standards and continue their professional development.

Professional membership with some of the PBs automatically includes anti-money laundering (AML) supervision.However this is not the case for all PBs, and supervision should not be assumed as included in membership. Some PBs require a separate registration for a member to also be supervised by them for AML purposes and may charge a further fee for this.

Each PBS has its own approach to how it manages this registration. Some of the PBSs will supervise an Accountancy Service Provider (ASP) business for AML purposes, and some PBSs will instead supervise the individual partners and principals who exercise control in an ASP business. For some PBSs, both the individuals and the ASP business may apply for AML supervision.

HMRC does not distinguish between a business and an individual who carries out ASP activity in that business; HMRC will register and supervise for AML purposes only the ASP business.

An ASP must ensure that it is supervised for AML purposes: if an ASP is not AML supervised by a PBS, it must apply to HMRC for supervision.

On applying, the ASP and its beneficial owners, officers and managers (BOOMs) will be subject to an approvals check, and they must be approved before HMRC will register the business. The check is to make sure that the business and its BOOMs are suitable people to carry out those roles. Under MLR 2017 regulation 26, there are limited grounds for HMRC to determine an ASP or its BOOMs as not approved. However, HMRC always considers applications to register very carefully, including assessing MLR 2017 compliance risks presented by an applicant. Where an ASP and its BOOMs pass the approvals check, HMRC is still able to consider other powers of MLR 2017 to refuse applications to register on other grounds of concern. Additional information on Approvals checks can be found here. (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh44382)

Additional information on BOOMs can be found here (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh45791).

Additional information on AML registration requirements can be found here. (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh40000)

When PBSs cannot agree who the appropriate AML supervisor should be, again the ASP must apply to HMRC for supervision. This could be the case for example where an ASP has several partners or principals, each holding their own professional membership with different PBs, or they are members of a PB that is not listed in Schedule 1 MLR 2017.

Unlike other professions such as doctors or solicitors, where it is only possible to practice after gaining a recognised qualification, anybody can set up in practice and call themselves an “accountant”. The profession therefore consists of qualified and unqualified accountancy practitioners. To practice as a qualified accountant a person must gain entry to one of the PBs.

This means HMRC’s supervised ASP population mostly consists of those with unqualified status.

It also includes former members of PBs, such as those who have qualified and allowed their PB membership to lapse whilst remaining in practice.

Although unqualified, a substantial proportion will have participated in training courses but did not complete their training or either did not take or did not pass final examinations. The unqualified industry population also includes persons who were once employees of HMRC (often tax inspectors). Many unqualified practitioners in accountancy roles are therefore highly competent to perform accountancy work and view themselves as professionals. The HMRC AML supervised population includes persons with a range of knowledge, experience and competence within the sector.

HMRC and the PBSs have a permitted information disclosure gateway under regulation 52 MLR 2017.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)