Anti-money laundering annual firm return
To support effective anti-money laundering (AML) supervision and compliance with the Money Laundering Regulations, all AAT AML-supervised firms are required to complete the AML annual firm return. The information you provide helps us to:
- identify and assess risks: we gather insights into the international and domestic risks of money laundering and terrorist financing
- adopt a risk-based approach: understanding your firm’s AML measures allows us to tailor our supervisory functions effectively
- maintain compliance: ensuring all supervised firms are up to date with their AML obligations is essential for maintaining the integrity of the financial system
- issue relevant guidance.
The AML annual firm return does not form part of your licence renewal. Both the AML annual firm return and your licence renewal must be completed separately.
Review your business details in your MyAAT account
Before 21 September 2026, review your business details.
Amending business details
To update any of the details below, use the Edit my details service:
- registered business name (not applicable to limited companies – email customer.support@aat.org.uk)
- registered business address (not applicable to limited companies – email customer.support@aat.org.uk)
- business email address
- business website
- indication of main business.
Adding/removing a business, changing type or ownership
To request changes to any of the details below, complete the AAT licensed member business details form (PDF) and email it to customer.support@aat.org.uk:
- adding a new business
- removing an existing business
- changing the business type (eg sole trader to limited company)
- changing business ownership.
Changes are usually processed within 10 working days, so allow sufficient time before the 21 September 2026 deadline.
Discontinuing your licence
If you no longer need your AAT licence, for example if you've ceased trading, email customersupport@aat.org.uk.
Information you'll need to complete the return
You'll be asked questions about your firm's AML controls and compliance measures.
To make completing the return easier, have the following information to hand before you start:
- your AAT membership number (exactly as in the email you received)
- your firm name (exactly as in the email you received)
- your AAT organisation number (exactly as in the email you received)
- your annual turnover
- the number of beneficial owners, officers or managers (BOOMs) at the firm (the full definition of BOOM can be found on our AML page)
- the total number of clients at your firm, including how many you have assessed as low, medium and high risk
- the number of clients who are considered cash intensive businesses (for example, nail bars, car washes, construction companies, barber shops, restaurants, cafes and bars)
- the number of clients operating in an industry typically considered high risk for money laundering or terrorist financing
- the number of politically exposed persons (PEPs) and/or high net worth individuals and/or wealthy individuals
- the number of clients your firm provides Trust or Company Service Provider (TCSP) services to, including how many receive TCSP services only
- the number of clients for whom your firm carries out Register of Overseas Entities verification checks
- the number of clients your firm has declined to engage with, or ended engagement with, following a risk assessment in the last 12 months
- the number of months since the firm last completed an AML compliance review and reviewed AML policies, controls and procedures
- the number of Suspicious Activity Reports (SARs) submitted in the last 12 months.
Please ensure you enter your AAT membership number, firm name and AAT organisation number exactly as they appear the AML annual firm return email or it could lead to your response not being recorded in AAT’s database and may result in future reminders being sent to you.
The form does not allow you to save progress or amend your response to each question. Please ensure you have all the above information ready before you start.
Completion time
The time needed to complete the return will vary depending on the size of your firm, the services you provide and the nature of your client base. While we recommend allowing up to 60 minutes to read each question carefully and provide accurate responses, most firms complete the return in around 25 minutes on average.
Confirmation of receipt
Within an hour of submission an email confirmation, along with a copy of your answers, will be emailed to you. Please check your mailbox (including your junk/spam folder) for an email from notifications@followups.typeform.io.
Consequences of non-compliance
Failing to submit the AML annual firm return within the specified timeframe will result in:
- immediate removal of AAT licences and professional memberships for all AAT licensed members within your firm
- cessation of AAT supervision for your firm under the Money Laundering Regulations
- notification to relevant authorities, including HMRC, as required by law
- publication of the non-compliance decision on AAT's Disciplinary outcomes and licensing and anti-money laundering decisions page.
You have no clients yet
If you have no clients yet but need to retain your AAT licence because you intend to provide services to them, you still need to complete the AML annual firm return.
All firms supervised by AAT must still have AML policies, procedures and controls in place ready for when they do take on clients, as a condition of holding an AAT licence under our Licensing Regulations. When completing the AML annual firm return, you’ll be asked if you have more than one client. If you do not, you’ll be directed to complete the questions that are relevant to all firms regardless of whether they’re actively providing services.
If you don't need your licence, email customer.support@aat.org.uk before 21 September 2026.
Further guidance on AML compliance
AAT has a range of resources available in the AAT Lifelong Learning Portal including short bitesize modules on AML.
Webinars include Cryptocurrency essentials and an AML scenario.
Once you're in the Learning Portal, look under Collections, and open "Featured CPD" or "Webinar CPD". Find the relevant CPD bitesize or webinar and click "Launch".
Further guidance and support on risk management and other components of Money Laundering Regulations compliance is available on our AML page as well as in the AML and ethics category in the AAT Knowledge Hub.
You can also contact us on +44 (0)20 7367 1347 or at aml@aat.org.uk.
