UK AML Registration Process: A Complete Guide [2025]

Whether you’re a solo accountant, a small bookkeeping firm, or a new financial services provider, anti-money laundering (AML) registration isn’t just a formality; it’s a legal necessity under UK law.

Firms handling financial transactions, client funds, or advisory services are subject to AML oversight under the Money Laundering Regulations 2017 (MLR 2017). That means before you can legally operate, you must be registered with a supervisory authority like HMRC or a professional body such as the FCA, ICAEW, or ACCA.

The process can be time-consuming and confusing, especially for smaller practices without in-house compliance teams.

In this guide, we break down the UK AML registration process step by step, including:

If you’re trying to navigate UK compliance requirements or preparing for your first AML inspection, this guide is built for you.

Who Needs to Register Under UK AML Regulations?

Not every business is automatically subject to AML obligations, but many are without realising it. If you handle client funds, manage transactions, or provide financial services, you likely fall under the UK’s AML supervision framework.

Regulated Businesses Under MLR 2017

According to the Money Laundering Regulations 2017, the following types of businesses must register for AML supervision:

• Accountants and bookkeepers, including self-employed professionals offering tax, payroll, or advisory services
• Trust or Company Service Providers (TCSPs) that help set up businesses or act as nominee directors
• Estate agents and letting agents involved in property sales or rental agreements over €10,000 per month
• Cryptoasset exchange providers and wallet custodians
• Art market participants dealing in works valued at €10,000 or more
• Independent legal professionals engaged in transactions involving client money

If you operate in any of these sectors, AML registration is mandatory before you begin providing services.

In 2023, HMRC supervised more than 30,000 UK businesses for AML compliance, with the majority being small firms and sole traders. Many were subject to audits within their first 18 months of registration.

Who do You Register With

Your supervisory authority depends on your profession. Here’s how it typically breaks down:

Sector	Supervisory Authority
General Accountants, Bookkeepers	HMRC
Chartered Accountants	ICAEW, ACCA, ICAS
Legal Professionals	Solicitors Regulation Authority (SRA)
Crypto Firms	Financial Conduct Authority (FCA)
TCSPs, Estate Agents, Art Dealers	HMRC

Even if you are already registered with Companies House or have a professional body membership, that alone does not meet AML compliance requirements. AML supervision is a separate obligation under UK law.

What Happens If You Don’t Register?

Failure to register before offering regulated services can lead to serious consequences:

• Civil penalties (fixed and variable fines)
• Criminal prosecution for trading unlawfully
• Suspension or termination of business operations

In 2022–2023, HMRC issued over £3.2 million in penalties to firms that failed to register or comply with AML supervision.

If you are unsure whether your firm qualifies, it’s safer to assume you do and verify directly with HMRC or your industry body.

The UK AML Registration Process: Step-by-Step

The AML registration process is a legal requirement for businesses operating in regulated sectors. If you plan to offer financial, legal, or property-related services, you must complete this process before engaging with clients. Here’s a clear breakdown of each stage involved.

Step 1: Identify the Correct AML Supervisory Body

Start by confirming which organisation regulates AML compliance for your sector. This will determine where and how you submit your application.

• Most accountants, bookkeepers, and TCSPs must register with HMRC
• Members of professional bodies such as ICAEW or ACCA will register through those organisations
• Cryptoasset firms are overseen by the Financial Conduct Authority (FCA)
• Legal professionals are typically supervised by the Solicitors Regulation Authority (SRA)

Identifying the correct body is essential to ensure your AML registration process begins on the right track.

Step 2: Prepare All Required Documentation

The application will require supporting documents that prove your identity, business structure, and AML readiness. These often include:

• Proof of business registration (e.g. Companies House or UTR reference)
• Identification for beneficial owners and senior management
• Business address verification
• Your AML risk assessment and written internal policy
• Details about the services you offer and the clients you work with

Having these documents ready helps avoid delays once the registration is underway.

Step 3: Complete and Submit the Application

You’ll submit your AML registration application either through the Government Gateway (for HMRC) or the relevant professional body’s online system. Be prepared to provide detailed information about:

• Your business structure and activities
• Ownership and control of the firm
• Your plan for meeting AML requirements in day-to-day operations

The information provided during this stage will be used to assess whether your business is fit for supervision.

Step 4: Pay the Registration Fees

Each supervisory body has its own fee structure. As of 2025:

• HMRC charges £300 per business premises and £40 for each responsible person
• FCA fees for crypto-related AML registration can range from a few thousand to over £10,000, depending on the firm
• Professional bodies may include the registration cost within your membership dues

Ensure you check the exact fee applicable to your category before submission.

Step 5: Complete the Fit and Proper Test

The final step of the AML registration process is a background check for all responsible individuals. This is commonly referred to as the Fit and Proper Test and typically involves:

• Confirming identity and right to work
• Criminal background checks
• Assessing financial soundness
• Verifying AML training or experience if required

This ensures that those overseeing AML compliance in your firm are qualified and trustworthy.

What Happens After the AML Registration Process?

Completing the AML registration process is just the start. Once your business is registered with a supervisory authority, you take on a set of ongoing responsibilities under the UK’s Money Laundering Regulations (MLR 2017).

These obligations apply whether you are a sole practitioner or part of a larger firm, and failing to meet them can result in penalties or removal from the AML register.

Ongoing Compliance Requirements

Once approved, your business must:

• Maintain a current AML risk assessment tailored to your services and client base
• Implement and regularly update an internal AML policy
• Conduct Customer Due Diligence (CDD) on all clients, and Enhanced Due Diligence (EDD) when necessary
• Keep detailed records of all checks, including the rationale behind client risk ratings
• Submit Suspicious Activity Reports (SARs) where required
• Provide AML training for staff members involved in regulated activity
• Cooperate with supervisory audits or compliance reviews

These requirements form part of the UK’s broader compliance framework, and they apply continuously after registration, not just at the point of onboarding.

In recent years, HMRC and other supervisory bodies have increased audit frequency, particularly for small firms. Many new registrants are reviewed within their first 18 months of approval.

Audit and Reporting Expectations

Your AML supervisory body may conduct scheduled or surprise inspections to review:

• Client onboarding records
• Internal AML controls
• Staff training history
• Recordkeeping systems
• Reporting procedures for suspicious activity

Inspections often include a request for evidence that checks were completed at the time of onboarding, not after the fact. That’s why keeping audit-ready records is not just a best practice, it’s a regulatory necessity.

Tools to Simplify Ongoing Compliance

Managing AML compliance after registration can be time-consuming, especially for solo practitioners and small firms. Manually collecting ID documents, performing due diligence checks, and maintaining audit trails leaves room for delays and errors. Fortunately, there are tools that can help automate many of these steps.

Where Digital Tools Make a Difference

Firms that rely on manual methods often face challenges like:

• Missing timestamps or version history during audits
• Friction in collecting ID and address verification
• Repetitive document requests to clients
• Inconsistent record-keeping between systems

These issues not only increase administrative load but also put firms at risk during supervisory reviews.

That’s why many UK firms now use compliance platforms that integrate Open Banking to streamline client onboarding and verification.

📚Guide to MTD Process in the UK

How Finexer Supports AML Compliance with Real-Time Bank Data

If you’re already registered and looking to reduce manual steps in your AML process, Finexer provides an Open Banking infrastructure that simplifies identity verification and audit preparation.

Here’s how Finexer fits into your compliance workflow:

• Verify Identity Through Bank Login
  Instead of requesting passport scans or utility bills, let clients authenticate through their bank. This confirms their legal name, account ownership, and address in seconds, directly from their financial institution.
• Instant Proof-of-Funds Checks
  For higher-risk clients or transactions, Finexer allows you to verify balances and spot suspicious financial behaviour without waiting for uploaded bank statements.
• Audit-Ready Compliance Logs
  Every verification creates a time-stamped report with matched details and consent tracking. This supports FCA-aligned reporting and reduces preparation time during reviews.
• Faster Onboarding, Fewer Drop-Offs
  Clients no longer need to upload documents or repeat steps across systems. This improves the onboarding experience while keeping you compliant behind the scenes.

By combining regulatory reporting requirements with real-time financial data, Finexer helps firms meet their AML obligations efficiently, without sacrificing accuracy or control.