Anti-money laundering whistleblowing

Whistleblowing is speaking up or raising a concern. If someone sees something wrong or unethical taking place in the workplace, they must be able to raise this within their organisation or to a regulator if appropriate.

If you identify an accountancy firm that is supervised by AAT and appears to be failing to adhere to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, you can report it confidentially to us. If information is provided to us on a confidential basis, we will take the appropriate steps to protect your identity. AAT strongly encourages both our members and members of the public to raise matters as soon as there is a genuine concern, in accordance with the procedure set out below.

How to report information to us

To enable us to review your information as quickly as possible, please email aml.whistleblowing@aat.org.uk providing as much information as possible, including:

  • the names of any individuals and/or firms involved
  • details of the alleged violation of a law, rule or regulation
  • any key dates
  • details of any internal procedures followed and the outcomes
  • a summary of the supporting evidence you have provided – is it known and substantiated?   

If you are not able to email the documents, please send your written enquiry and documentary evidence to:

Professional Standards
AAT
140 Aldersgate Street
London, EC1A 4HY

On receipt, your disclosure will be allocated to an appropriate investigating officer in the Professional Standards team, who will then carry out an assessment in accordance with the Anti-money laundering whistleblowing policy to determine whether there are grounds for action to be taken. It may be that a concern you've raised turns out to be unfounded when investigated further but this doesn't mean that you shouldn't have raised it in the first place.

Alternatively, you can call on +44 (0)20 7367 3182 to discuss, in confidence, your concerns about an AAT member or an AAT supervised firm.

How we'll use the disclosure

Depending on the information provided, we may take different types of action in response, including:

  • keeping the complaint on record and monitoring the firm closely
  • deciding a practice assurance review visit should take place
  • making a confidential report to law enforcement agencies
  • using the information as part of a formal investigation into a firm.

How we'll keep you informed

We'll write to confirm receipt of your information and may contact you again if we require anything further from you, unless you specifically ask us not to.

Firms not supervised by AAT

If you identify an accounting service provider or trust and company service provider that doesn't appear to be supervised under the Money Laundering Regulations, or disregarding the requirements of the regulations, you can contact:

  • the firm's relevant supervisory body
  • the MLR Central Intervention Team at MLRCIT@hmrc.gov.uk.

These contact details are solely for the purpose of reporting matters relating to possible breaches of the Money Laundering Regulations. They are not to be used in relation to general complaints or queries regarding the professional conduct of AAT members. Any matters of this nature should be reported via the AAT complaints process.

Other helplines available

There are several other helplines available to AAT members which may provide practical advice for a range of scenarios. The general procedure is to ask for your name and membership number but you're welcome to remain anonymous should you wish to do so. Please note that any guidance is based on information you provide us and may not be treated as legal advice or a formal ruling.

Anti-money laundering enquiries

AAT’s AML helpline offers advice on all aspects of complying with the Money Laundering Regulations, such as advice on how to report suspected illegal activity. If any information discussed leads us to suspect money laundering activity, you'll be required to make a report to law enforcement agencies. To discuss any questions you might have, call us on +44 (0)20 7397 1347 or email aml@aat.org.uk.

Ethics enquiries

AAT’s ethical helpline will help if you need to talk about an ethical dilemma at work or within your firm. We can discuss the situation, the options available to you and the safeguards you can put in place to ensure you continue to work in an ethically responsible way. To discuss any ethical questions you might have, call us on +44 (0)20 7397 1350 or email ethics@aat.org.uk.

Protect – Speak up, Stop Harm

Protect (formerly Public Concern at Work) are leading experts in whistleblowing. They operate a free, confidential advice line.

For whistleblowing advice you can call +44 (0)20 3117 2520, email whistle@protect-advice.org.uk or visit their website.

Useful guides and publications