Client due diligence for accountants: are your onboarding checks fast enough?

TL;DR: Accountants, tax advisers and bookkeepers are in scope under the MLRs 2017 and must identify and verify clients from a reliable independent source, keep records for five years, and maintain ongoing monitoring, according to OneID analysis. The operational challenge is not the rule itself but making onboarding fast enough for thin-file clients without weakening identity assurance.

Editorial analysis by NHI Mgmt Group, based on content published by OneID: “AML and KYC for accountants: client due diligence under the MLRs 2017”.

Key questions

Q: What should accountants do when a client cannot be verified from one data source?

A: They should move to a documented fallback that uses additional reliable independent sources rather than accepting weaker evidence.

Q: Why do AML onboarding checks slow down legitimate clients?

A: They slow down when firms design around manual document collection instead of verified identity data.

Q: How should firms separate client due diligence from wider AML duties?

A: Client due diligence confirms who the client is and why the engagement exists.

Practitioner guidance

• Define the evidence threshold for client identity Set a clear standard for what counts as a reliable independent source before staff begin onboarding.
• Add a thin-file fallback path Create a separate workflow for newly formed companies, recent arrivals and other low-footprint clients.
• Separate verification from wider AML controls Keep client identity verification distinct from PEP and sanctions screening, source-of-funds checks, ongoing monitoring and suspicious activity reporting.

Bottom line: Accountancy and tax firms in scope of the MLRs 2017 must verify client identity from a reliable independent source and keep that evidence current.

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