Anti-money laundering annual firm return

As part of our commitment to ensuring effective compliance with the Money Laundering Regulations, all AAT anti-money laundering (AML)-supervised firms are required to complete the AML annual firm return.  

By completing this return, your firm 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.

This is a regulatory requirement that provides a snapshot of your firm’s AML measures, which is separate from the licence renewal process, and so you need to complete the AML annual firm return separately from your AAT licence renewal.

Information you'll need to complete the return 

You’ll be asked questions about your AML policies, controls and procedures and will need to have to hand:

• your AAT membership number (found in the email you received)
• your firm name (found in the email you received)
• your AAT organisation number (found in the email you received)
• 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 the firm
• the number of clients the firm has assessed as being low, medium and high risk
• the number of politically exposed persons (PEPs) and/or high net worth individuals the firm is providing services to, if applicable
• the number of clients the firm is providing trust and company services (TCSP) services to, if applicable
• the number of months since the firm last completed an AML compliance review
• the number of Suspicious Activity Reports (SARs) submitted in the last 12 months, if any. 

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 completion time will vary for each firm depending on the number of clients, the types of services being provided, and whether there are higher risk clients present. We would expect firms to allow up to 60 minutes to ensure they’ve read each question carefully and answered accurately. However, on average, it takes firms approximately 25 minutes to complete.

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.