The CCAB guidance, often called AMLGAS, is the accountancy sector’s practical manual on the Money Laundering Regulations 2017, the Proceeds of Crime Act 2002 and related law. The current edition is based on the law as at 1 July 2026 and replaced the 2023 version. It is not law and following it is not a complete defence, but supervisors and the courts must consider whether a firm followed relevant guidance approved by HM Treasury, so in practice it sets the standard a firm is judged against.

What is AMLGAS and who produces it?

The full title is the Anti Money Laundering and Counter Terrorist Financing Guidance for the Accountancy Sector. According to the Chartered Institute of Taxation, it is prepared jointly by the CCAB bodies (ICAEW, ACCA, ICAS, Chartered Accountants Ireland and CIPFA) and approved by the UK accountancy supervisory bodies, including CIOT and ATT. ACCA describes it as covering money laundering, terrorist financing and proliferation financing, and says it is intended for anyone providing audit, accountancy, tax advisory, insolvency, or trust and company services in the UK.

It is not only for members of professional bodies. HMRC’s page titled “Accountancy sector guidance for money laundering supervision”, which applies to the accountancy service providers HMRC supervises, links to the 2026 CCAB guidance as its guidance document, alongside HMRC’s own published assessment of risks common to accountancy service providers.

How is the guidance structured?

The guidance is organised in numbered chapters with lettered appendices, and the professional bodies’ own helpsheets cross refer to it by chapter. ICAEW’s helpsheet for smaller practices, for example, directs members to these parts:

Topic Where ICAEW points members Related page
Firm wide risk assessment Chapter 4 Firm wide AML risk assessment
Client due diligence, EDD and reliance Chapter 5 and Appendix B Customer due diligence
Suspicious activity reports Chapter 6 Suspicious activity reports

ICAEW’s electronic CDD helpsheet refers to Appendix B for the broad hierarchy of identity documents, with documents issued by government departments, agencies or a court being the most reliable. Two supplements sit alongside the main text:

  • Supplementary guidance for tax practitioners, which CIOT says was developed with ATT, ICAEW, ACCA, ICAS and HMRC and covers the interaction between AML compliance and tax offences. CIOT confirmed it was not changed in 2026.
  • The insolvency appendix, which ICAEW lists as Appendix F, guidance for insolvency practitioners. ICAS recorded that HM Treasury approved both the tax and insolvency appendices.

ACCA notes that the 2026 publication comes with a separate document outlining the changes from the previous edition, which is the quickest way for a firm to update its procedures.

What changed in the 2026 edition?

ICAEW’s August 2026 summary explains that the guidance was updated for the Money Laundering and Terrorist Financing (Amendment) Regulations 2026, which came into force on 30 June 2026 and made 15 targeted changes to the 2017 Regulations. The main changes are:

  • enhanced due diligence applies to transactions that are unusually complex or unusually large, which ICAEW says refines rather than adds to the obligation;
  • mandatory high risk third country EDD is limited to FATF call for action countries, with firms encouraged to use the AASG Risk Outlook for wider jurisdiction risk;
  • monetary thresholds converted from euros to sterling;
  • selling off the shelf companies brought within trust or company service provider activity;
  • clarification, at HM Treasury’s request, that the general EDD triggers are non exhaustive and non prescriptive, and that regulation 28(11)(a) makes source of funds checks necessary when a transaction is inconsistent with what the firm knows of the client;
  • a new section on sources of evidence with a passport as the preferred document, and a statement that digital verification services should be certified and on the DVS register (see electronic identity verification).

What legal status does the guidance have?

HM Treasury’s June 2026 response on supervision reform puts it plainly: following guidance is neither mandatory nor a statutory defence. Its weight comes from several provisions that tell decision makers to take it into account:

  • Regulation 86(2) of the Money Laundering Regulations 2017: in deciding whether a person has committed the criminal offence of contravening a relevant requirement, the court must decide whether the person followed relevant guidance issued by the FCA, or issued by another supervisory authority or appropriate body and approved by the Treasury.
  • Regulation 76(6): a designated supervisory authority deciding whether to impose a civil penalty must consider whether the firm followed guidance of the same kind.
  • Section 330(8) of the Proceeds of Crime Act 2002: in a failure to disclose case the court must consider whether the person followed relevant guidance approved by the Treasury and published in an approved manner. HM Treasury notes that section 331(7) and section 21A(6) of the Terrorism Act 2000 work the same way.

The same response notes that regulations 19, 21, 24 and 35 allow firms to take account of guidance when deciding what measures are appropriate and proportionate. ICAS records that earlier editions, including the June 2023 guidance, were approved by HM Treasury, and ICAEW’s summary of the 2026 edition notes that some areas were reviewed at HM Treasury’s request.

How do supervisors use it?

Supervisors treat the guidance as their statement of what compliance looks like. CIOT tells firms it supervises that they should follow it, and that members supervised elsewhere must take account of their own supervisor’s guidance. Under regulation 28(16) a firm must be able to show its supervisor that its CDD measures are appropriate to the risks, including risks identified by the supervisor and in information it provides under regulation 47. A file that follows the guidance, or explains a reasoned departure from it, is far easier to defend at a monitoring visit. More on how supervision works is in AML supervision for accountants.

What happens to the guidance when the FCA takes over supervision?

HM Treasury’s June 2026 response says responsibility for issuing and approving AML guidance for professional services firms will transfer to the FCA. It expects accountancy guidance to stay practitioner drafted, with the FCA approving it and HM Treasury keeping a veto, and expects the CCAB arrangement to be reformulated because professional bodies will lose their AML role. HM Treasury will continue to approve guidance in the meantime. It intends to consult on the veto mechanism in late 2026 and lay amending regulations in 2027. The wider timetable is covered in AML supervision reform and the FCA.

How should a small practice use it day to day?

Illustration only. A sole practitioner supervised by a professional body reads the 2026 change document in August. She updates her written procedures in three places: the EDD trigger wording now says “unusually complex or unusually large”; the high risk country section refers to the FATF call for action list and the AASG Risk Outlook; and her identity procedure now requires that any electronic provider is on the DVS register. She records the date of the review, briefs her one employee and notes the change in her training log. Her procedures cross refer to the chapters of the guidance so that a reviewer can see where each control comes from. See AML policies, controls and procedures.

What mistakes do firms make with the guidance?

  • Working from the 2023 edition, or from template procedures written before 1 July 2026.
  • Treating it as a checklist instead of a description of a risk based approach; the 2026 edition stresses that its examples are non prescriptive.
  • Assuming that following it guarantees immunity. It is a factor the court and supervisor must weigh, not a defence.
  • Tax advisers ignoring the tax supplement, and insolvency practitioners ignoring the insolvency appendix.
  • Departing from it without recording why.

Solar Protect runs fee protection schemes for accountancy and bookkeeping practices. See how our accountant schemes work or read fee protection schemes for accountants.

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Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.