Landmark's Blog Library

general articles

A mismatch of ID requirements

By David Winch / 1st March 2025

Companies House will, over 2025 and 2026, be requiring all company directors and PSCs to have their identity verified, but there is a mis-match between the ID requirements under MLR 2017 and the ID requirements of Companies House.

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TCSP v ACSP clarification

By David Winch / 1st February 2025

These days we are drowning in acronyms. So I thought it would be useful for me to spell out the significance of TCSP and ACSP and the difference between them.

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Client disengagement

By David Winch / 1st January 2025

From time to time an accountant’s relationship with one of his or her clients will come to an end. The change may come about by mutual consent – or there may be an acrimonious falling out!
But whatever the reason, there needs to be clarity about the detail around the ending of the relationship. In most cases this can best be handled by the accountant sending the departing client a disengagement letter.

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PSCs – what disclosures are required?

By David Winch / 1st December 2024

UK Companies are required to record information about their PSCs (people with significant control) on the PSC Register at Companies House. Over the next two or three years Companies House will be requiring the IDs of PSCs and company directors to be verified.

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Is your AML 20 years out of date?

By David Winch / 1st November 2024

You would not give tax advice based on the tax requirements of 2003 – but is your understanding of your firm’s AML obligations 20 years out of date? There are now ten fundamental requirements for accountants, bookkeepers and tax advisers subject to the UK money laundering regulations.

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AML and the very small client

By David Winch / 1st October 2024

What are the money laundering risks associated with a very small client’s business – and how should AML issues be addressed?

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AML and the solo practitioner

By David Winch / 1st September 2024

What does the solo practitioner – a provider of accountancy, bookkeeping or tax services, who has no staff or subcontractors – have to do to comply with anti-money laundering requirements in the UK?

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AML annual review – time down the drain?

By David Winch / 1st August 2024

A lesser-known requirement of the Money Laundering Regulations 2017 concerns the monitoring and management of compliance with the firm’s AML policies, controls and procedures. When is the best time for a review?

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How bad are accountants at AML compliance?

By David Winch / 1st July 2024

What proportion of accountants in the UK fail to comply with the Money Laundering Regulations 2017 – and what are the most common failings?

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Are HMRC AML late registration penalties fair?

By David Winch / 21st June 2024

This blog post is about financial civil penalties that HMRC levy where a business is late registering with HMRC for AML supervision. Are these penalties fair? How are they calculated? How can a penalty be reduced? Can the penalty be appealed?

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Assisting with tax – a trap for the unwary!

By David Winch / 6th May 2024

Some years ago a minor tweak was made to the wording of the Money Laundering Regulations 2017 which may catch out specialist firms.

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Outsourcing and AML compliance

By David Winch / 2nd April 2024

Accountants in the UK are increasingly outsourcing detailed bookkeeping, accountancy and payroll work – taking advantage of lower staff costs overseas. But what are the implications for the AML compliance requirements on the UK based firm?

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20 years of MLR for accountants

By David Winch / 1st March 2024

20 years ago, on 1 March 2004, the Money Laundering Regulations 2003 came into force. Maybe we should celebrate the anniversary with a cake!
This article briefly highlights some key steps in the evolution of the MLR over 20 years.

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Libby Walklett head in hand photo

What’s the worst that can happen?

By David Winch / 18th February 2024

I’m often asked, “What’s the worst that can happen if my firm does not comply with the money laundering regulations?” But instead let’s focus on fixing the problem – starting is the hardest part!

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AML Compliance and accountancy sub-contractors

By David Winch / 4th January 2024

A question we are often asked is, ‘Do sub-contract accountants and bookkeepers have to register themselves separately for AML purposes as accountancy service providers?’

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