External bookkeepers are considered 'relevant persons' under the scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs).
Therefore, if you are providing a bookkeeping service to clients, or are seen as carrying out bookkeeping 'by way of business', you must:
- be supervised by an HM Treasury appointed supervisory authority, such as ICB
- put in place certain controls to identify, prevent and report money laundering offences – known as anti-money laundering or AML
Anti-Money Laundering Supervision (AML)
Members with an ICB Practice Licence are automatically supervised by ICB under the MLRs. As an ICB Practice Licence holder, compliance with the MLRs is dependent on you satisfying the requirements of the MLRs as well as ICB requirements as your supervisor. Please refer to the printable AML To Do List download for more information.
> AML To Do List on the AML Forms & Checklists page
> Log in to AML online to update your online anti-money laundering records
> Log in to MyICB to update your details, add BOOM information, DBS Basic Checks, and check your membership status
> Apply for a Practice Licence
Approval of beneficial owners, officers and managers (BOOMs) – reviewing criminal records
ICB must check that supervised practices comply with Regulation 26 and that all beneficial owners, officers and managers (BOOMs) do not have a relevant criminal conviction.
ICB can only approve a BOOM if we have received a basic criminal record check certificate for them.
Every newly appointed BOOM must obtain a criminal record check at the time they become a BOOM and provide it to us for approval.
> Read more
Detailed AML Guidance for ICB supervised practices:
> AML Guidance
Confidential AML Whistleblowing hotline:
If you believe a practice supervised by ICB is breaching the Money Laundering Regulations, you can raise your concern confidentially.
0203 405 7581
If you come across a bookkeeper or bookkeeping practice, that does not appear to be supervised under the Money Laundering Regulations or appears to be ignoring the regulations and isn’t supervised by ICB you can contact the MLR Central Intervention Team:
Supervision by another body
You need only have one AML supervisor. If you are a member of another HM Treasury appointed supervisor, such as ICAEW or ACCA, please forward a copy of supporting documents to email@example.com
As an ICB member in practice you are still required to hold a Practice Licence even if you have an alternative AML supervisor.
Supervision of non-members
ICB is pleased to extend its anti-money laundering supervision scheme to practising members of the following bodies:
Please contact us if you would like further information
0203 405 4000
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