Guide · Accountants
AML checklist for accountants (EU baseline)
Accountants are an anti-money-laundering obliged profession across the EU, which means checks on a new client are a legal duty, not an optional courtesy. This guide sets out the EU-level baseline: why the duty exists, what customer due diligence actually means for an accounting client, and where to look for your own country's exact document list.
- Accountants are AML-obliged entities under EU law, alongside auditors and tax advisors
- Due diligence scales with risk: standard, or enhanced for higher-risk clients
- Exact document lists are set at national level, not EU level
Why are accountants an AML-obliged profession at all?
Anti-money-laundering law in the EU, currently the fourth and fifth AML directives and moving to the directly applicable Regulation (EU) 2024/1624, the AMLR, names accountants, auditors and tax advisors as obliged entities alongside banks and other financial firms. The reasoning is straightforward: accountants sit close to a client's money, company structure and transactions, which makes an accounting firm a plausible point for laundered funds to look legitimate. Being obliged does not mean every client is suspect. It means your firm has a legal duty to check who it is dealing with before, and sometimes during, the relationship, and to keep a record that it did.
What is customer due diligence, concretely, for an accounting client?
Due diligence means identifying the client and verifying that identity from a reliable, independent source, such as an identity document, and doing the same for any beneficial owner behind a company client. You also need to understand the purpose and intended nature of the relationship, in plain terms, what the client actually needs from you, and keep watching the relationship over time rather than checking once and filing the result away. For an individual client this is usually straightforward. For a company client it means working out who ultimately owns or controls it, which is not always the name on the incorporation documents.
When do you need enhanced due diligence instead of standard?
Enhanced due diligence applies when a client or a transaction carries a higher money-laundering risk: a politically exposed person, a client or counterparty in a high-risk country, a complex or unusually large transaction with no clear business rationale, or a relationship conducted entirely at a distance with no face-to-face contact. Enhanced measures typically mean collecting more evidence of identity and of the source of funds, and getting senior sign-off before taking the client on. Standard due diligence is the default for an ordinary local client with a straightforward, explainable need for accounting services.
What is a beneficial owner, and how do you actually identify one?
A beneficial owner is the natural person or people who ultimately own or control a company client, directly or through a chain of other entities, even if their name never appears on a contract. In practice you ask the client to name them, then verify that answer against a reliable source, in many EU states a public or restricted beneficial ownership register, plus company documents such as the shareholder register. Where ownership is spread thinly and no single person clears the usual control threshold, the people who exercise control by other means, such as senior managers, may need to be treated as the beneficial owners instead.
What records do you have to keep, and for how long?
Keep the identity evidence you collected, the documents supporting the beneficial ownership check, and a record of the transactions or services carried out for the client. Exact retention periods and the required record format are set at national level rather than uniformly across the EU, so check the country-specific guide for your jurisdiction rather than assuming one EU-wide number. What stays constant across countries is the underlying obligation: the record has to be complete enough that a supervisor, years later, can reconstruct why your firm was satisfied this client was who they said they were.
How this maps to a workflow: form, ID check, screening, sealed file
In practice this checklist becomes four steps in one client-intake link: a form collecting the client's and any beneficial owner's details, an identity verification step for each of them, a sanctions and politically-exposed-person screening step, and a signed engagement letter sealed into the same file as the evidence collected. Building it as one flow means the due diligence record and the engagement paperwork live together automatically, instead of a spreadsheet in one place and signed documents in another.
In Braigest
Due diligence as one step in client intake, not a separate spreadsheet
The AML screening step in a Braigest workflow runs sanctions and PEP checks and keeps the result with the client's file. It is available from the Practice plan at €149/month.
Frequently asked questions
Are all accountants AML-obliged, or only some?
Under EU law, accountants, auditors and tax advisors are named as obliged entities as a profession. Some national laws narrow this by activity or client type, so check your own supervisory body for the exact scope.
Do I need to run a check on every single client?
Yes, at least standard due diligence, though the depth scales with risk. A long-standing local client with a simple need is a lighter check than a new company client with an unclear ownership structure.
What if a client refuses to provide identity or ownership information?
Most national implementations require you to decline or end the relationship if you cannot complete due diligence, and some require considering whether the refusal itself is worth reporting. Check with your professional body for the exact duty in your country.
Is this checklist enough on its own, or do I need my country's specific rules too?
This is the EU baseline. Document lists, retention periods and thresholds are set nationally, so use this alongside your country's specific guide, such as the Romanian, Spanish or Italian rules linked from this site.
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