ECSH52625 - Business sectors supervised by HMRC: accountancy service providers: general risks in the accountancy service provider (ASP) sector
Source: gov.uk (2025-07-18)


Within the services provided by accountancy service providers (ASPs) to their clients, there is a risk of exploitation by criminals in order to launder illicit monies and conceal assets. Common risks throughout the sector may present as, but are not limited to, the following.
- Criminals may purchase legitimate businesses that can then be used to launder illicit funds. They can use it as a cover for other illicit activity.
- Businesses with high levels of cash turnover are particularly appealing as they give criminals the opportunity to introduce illicit cash into the business by inflating the takings. The criminal then has an explanation for their apparent wealth which appears to be derived from a legitimate source.
- The customer operates in a supervised sector and is not registered.
- The customer is supplying goods and services to criminals, is accepting high value payments and may even be an unregistered High Value Dealer (HVD).
- The customer is involved in tax evasion. Money retained through tax evasion is criminal property and therefore the provision of ASP services in relation to these funds may constitute money laundering.
Supply chains

A supply chain is created when a relevant service is provided to an end user via an intermediary. ASPs can provide a wide range of services, and a customer may utilise a number of ASPs for different services to conceal activity and ensure only a limited picture of their activity is presented to any one ASP.

Supply chains can compound the risks presented by individuals and intermediaries involved with the provision of ASP services, by placing distance between the ASP and the end user of the service which could be used for the purposes of providing anonymity. Where supply chains involve intermediaries or end users who are based outside of the UK, the risk is further increased; this combines the risk of the service being provided overseas or to high-risk third countries with risk inherent to supply chains.

Further information regarding risks can be found within:
- The National Risk Assessment of money laundering and terrorist financing 2025 (https://assets.publishing.service.gov.uk/media/6877be59760bf6cedaf5bd4f/National_Risk_Assessment_of_Money_Laundering_and_Terrorist_Financing_2025_FINAL.pdf)
- HMRC’s Understanding risks and taking action for accountancy service providers (https://www.gov.uk/government/publications/understanding-risks-and-taking-action-for-accountancy-service-providers/understanding-risks-and-taking-action-for-accountancy-service-providers)
- CCAB anti-money laundering guidance for the accountancy sector (https://www.gov.uk/government/publications/anti-money-laundering-guidance-for-the-accountancy-sector)
- FATF guidance for a risk-based approach for the accounting profession (https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Rba-accounting-profession.html)
- European Commission supranational risk assessment of money laundering and terrorist financing (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52019DC0370%20)
(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

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