A folder of passports from years ago
When each client joined, someone collected ID, ran a check and filled in a risk assessment form. Those are saved somewhere, in the practice tool, a shared drive or a filing cabinet. Since then, directors have changed, businesses have started trading in different areas, and some of the passports have expired.
Nobody knows which files are up to date, because the review date was never recorded in a place that reminds anyone. Then your supervisory body announces a review of firms like yours, and the partner spends evenings going through folders.
Why AML upkeep slips
The checks are a gate at the start of a relationship. Once the client is through, the file goes quiet. Ongoing monitoring is expected, but the events that should trigger a fresh look, a new director, a change of business activity, unusual transactions, happen in places the AML file never sees, like Companies House or the client's ledger.
Everything else in a bookkeeping firm has a monthly rhythm. AML has a rhythm measured in years, so it falls out of anyone's routine.
What your firm must do, and how often, is set by your supervisory body and your own policy. The system does not decide that. It makes sure your chosen rules are followed and recorded.
What stale AML records cost
Gaps are uncomfortable when someone asks to see your records, and fixing them in a rush is slow and disruptive. Clients find it odd to be asked for ID years later with no warning. And the real purpose, knowing who you are working for and spotting when something changes, is weakened if nobody is looking.
| Trigger for a fresh look | Where it usually shows up first |
|---|---|
| Review date reached | Nowhere, unless tracked |
| New director or owner | Companies House filings |
| ID document expired | The document itself |
| Change in business activity | Ledger, new income types |
| Unusual transactions | The bookkeeper's monthly work |
How we build an AML register for your firm
- We gather what you already hold per client, ID documents, check results, risk assessments and dates, into one register linked to your practice tool, with a person checking anything the import is unsure about.
- Each client gets a review date based on the risk level and the intervals your policy sets.
- We watch Companies House for changes in officers and persons with significant control for your company clients, and flag any change against the register.
- Document expiry dates are recorded, so an expired passport creates a prompt rather than a surprise.
- When a review is due, the client receives a request through a secure link to confirm details and upload any updated documents, and the reviewer completes the assessment form in the same place.
- Where you use an electronic ID verification provider, we pass the new details to it and store the result against the client.
- Bookkeepers have a simple way to flag a concern from their monthly work, which goes to your nominated officer rather than into a general inbox.
The register is a record and a set of prompts. The judgement about risk and any reporting decision stays with your nominated officer.
A register you can show
Reviews happen when they are due, in small numbers each month, instead of in a rush. Changes at a client come to your attention when they happen. The partner can open a single view and see every client's status. When someone asks how the firm keeps its records current, the answer is a screen rather than an evening of searching.
Is your AML file up to date?
- Client ID was checked at onboarding and not since.
- Review dates are not recorded anywhere that sends reminders.
- You would not know if a client company changed its directors.
- Some ID documents on file have expired.
- Bookkeepers have no clear route for raising a concern.