AML in auditing and accounting: four steps to a risk-based approach

Auditors and accountants play a far greater role in financial integrity today than ever before. Beyond verifying figures and financial statements, they are key to detecting and preventing money laundering. 

Under the EU’s Anti-Money Laundering Directives (AMLDs), these professionals are required to apply a risk-based approach, identifying, assessing, and mitigating financial crime risks before they escalate.

This article explains how auditing and accounting firms can build effective AML programmes, the risks unique to their profession, and the four steps to implementing a compliant, risk-based approach.

Failing to comply does more than attract fines. It can lead to reputational damage, loss of client confidence, and increased regulatory scrutiny across jurisdictions, all of which are far costlier in the long run.

Why auditors and accountants face AML risk

Auditors and accountants have access to detailed financial data and client relationships that criminals can exploit to disguise illicit activity. Money laundering often hides in plain sight, through legitimate-looking accounts, reports, or transactions that conceal illegal funds.

These professions face distinct exposure through:

• Client misuse: Fraudulent clients using professional credibility to legitimise dirty money.
• Geographic exposure: Serving clients with operations in high-risk or opaque jurisdictions.
• Reputational risk: Even a single compliance failure can damage years of trust and professional standing.

By understanding how financial crime can intersect with their work, firms can take proactive steps to ensure their expertise supports prevention rather than exploitation.

Four steps to a risk-based AML approach

A risk-based approach allows auditing and accounting firms to design AML frameworks that fit their own operations, client base, and risk profile. 

It’s about prioritising where the threats are highest and applying proportionate controls that evolve over time.

1. Identify money laundering and terrorist financing risks

Begin with a clear understanding of where risk exists within your firm. Assess:

• The nature of the services you provide
• The types of clients you serve
• Geographic exposure and transaction channels
• Emerging risks in relevant industries 

2. Evaluate the risk level

Use structured assessments to measure both likelihood and impact. Document the results, seek management approval, and ensure that the findings guide decision-making across departments.

3. Reduce the risks

Develop a programme that integrates the following measures:

• Know your customer (KYC): Apply enhanced due diligence for high-risk clients such as politically exposed persons (PEPs).
• Reporting: Establish clear procedures for identifying and reporting suspicious transactions.
• Training: Ensure staff stay informed on evolving AML threats, regulatory expectations, and red flags.
• Internal controls: Maintain clear accountability, periodic independent reviews, and governance oversight.

4. Monitor and update

Risk management is an ongoing process. Review your risk assessments, controls, and client base regularly to ensure your framework remains effective as financial crime patterns and regulations evolve.

A structured risk-based approach satisfies regulatory requirements and helps firms operate with confidence, clarity, and consistency.

How Trapets supports auditors and accountants

Trapets KYC makes it easy for accounting and auditing firms to comply with the money laundering law. 

In one solution, you can easily collect customer data, conduct risk assessments and ensure regulatory compliance, with user-friendly processes that save time and reduce administrative work.

Act now

Financial integrity begins with trusted professionals. Strengthen your AML programme, safeguard your reputation, and lead your industry by example. Future-proof your AML work with Trapets’ automated monitoring and screening solutions.