AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Every UK accountancy practice must be supervised for anti-money laundering under the Money Laundering Regulations. If you are a member of a professional body such as ACCA or ICAEW that supervises you, you register with that body; otherwise HMRC supervises you. GOV.UK states that trading while not registered is a criminal offence, so apply before you take your first client.
Nigerian accountants in the UK, many ACCA or ICAN qualified, often start a practice to serve the community: Self Assessment returns for landlords and contractors, company accounts for small businesses, and tax help for people with income in both countries. Before the first engagement letter, the practice needs an anti-money laundering (AML) supervisor. This guide explains who supervises whom and what supervision requires.
Who must be supervised
The Money Laundering Regulations cover "accountancy service providers": broadly, businesses that provide accountancy services to other people by way of business, which in practice takes in bookkeeping, payroll, tax work and preparing accounts or returns. If you are unsure whether a service is covered, ask HMRC or your professional body. Each must have a supervisory authority.
| Your position | Your AML supervisor |
|---|---|
| Member of a professional body that supervises its practising members (for example ACCA or ICAEW) | That professional body; you do not register with HMRC |
| Not supervised by a professional body (for example a bookkeeper or tax agent with no supervising membership) | HMRC |
| Qualified overseas only (for example ICAN membership alone) | Check whether a UK professional body will supervise you; if not, HMRC |
A Nigerian qualification on its own does not give you a UK supervisor. Many diaspora accountants either join a UK body that supervises practising members or register with HMRC.
When to register
GOV.UK says trading while not registered is a criminal offence and may also lead to a penalty. It also says that, other than certain business types such as money service businesses, businesses can trade while their application is being processed. In practice: submit your application before you take on any client, and keep proof of the date.
Fees
HMRC charges a fee for each premises you register, including your home address if you work from home with no other business address. The amounts are on HMRC's registration fees page; check them when you apply. Professional bodies set their own practising certificate and supervision fees.
What supervision requires of you
- A firm-wide risk assessment of money laundering risks in your client base, services and delivery channels.
- Policies, controls and procedures that match those risks.
- Customer due diligence on every client: identity, beneficial owners of companies, and the purpose of the relationship, with enhanced checks for higher-risk clients.
- Training for anyone in the practice.
- Record keeping of checks and transactions.
- Suspicious activity reports to the National Crime Agency where you know or suspect money laundering. The Law Society explains that the NCA has a notice period of 7 working days from the day after a report seeking consent, and a further 31 calendar days if it refuses.
Clients with links to Nigeria
Clients with income, property or companies in Nigeria are not high-risk simply because of the country, but your risk assessment must consider where clients and their money come from. Expect to verify the source of funds for large inflows, understand Nigerian company ownership (see CAC persons with significant control rules), and keep evidence. Our guide to declaring Nigerian income on Self Assessment covers a common service you will provide.
Clients can check you
HMRC publishes a register of businesses it supervises, as a downloadable spreadsheet showing registration number, business name, trading name, part of the postcode, date supervised and sectors. Applicants do not appear until registered, and inclusion is not an endorsement. Professional bodies have their own directories.
What happens if you get it wrong
Supervisors can visit, ask for your risk assessment and client files, and take action where controls are missing. For a small practice the most common failings are a missing or generic risk assessment, identity checks done only at the start and never refreshed, and no record of why a higher-risk client was accepted. Each of these is cheaper to fix before the first client than after the first review. Keep a simple file per client showing the checks done, the risk rating and the date of the next review.
Steps
- Decide on your supervisor: your professional body or HMRC.
- Apply, pay the fees and keep the confirmation.
- Write your risk assessment and policies before onboarding clients.
- Set up a client due diligence checklist and file.
- Draft engagement letters and set up professional indemnity insurance as your body requires.
Where Pryme fits
A practice serving clients in both countries can bill in pounds and naira from one Pryme Business Account. The Compliance agent can keep due diligence reminders and review dates for a person to approve.
Questions people ask
Do I need AML supervision to start bookkeeping in the UK?
Yes. Bookkeeping for others by way of business is an accountancy service, and you need a supervisor: your professional body or HMRC.
Can I start taking clients before HMRC confirms my AML registration?
GOV.UK says businesses other than certain types such as money service businesses can trade while their application is processed. Trading without having registered at all is an offence, so apply first.
Does ICAN membership cover UK AML supervision?
An overseas body does not supervise UK practices under the UK regulations unless it is a listed supervisor. Check with a UK professional body or register with HMRC.
How can a client check my AML registration?
HMRC publishes a supervised business register spreadsheet; professional bodies have their own directories.
Sources
- GOV.UK: Money Laundering Regulations, who needs to register (updated 23 Aug 2023) · accessed Oct 2026
- GOV.UK: check if a business is registered for money laundering supervision (updated 19 Oct 2026) · accessed Oct 2026
- Law Society: your AML questions answered · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.