Free AML templates for UK firms
Five editable Word templates for small estate agents, letting agents, accountants and bookkeepers: AML policies, a firm-wide risk assessment, a client risk assessment form and a CDD checklist. Updated for the 2026 changes to the Money Laundering Regulations.
- Estate & letting agents
AML policy and procedures for estate agents
A written policy for a small estate or letting agency, built around HMRC’s guidance on who your customers are and when checks must be done.
What’s inside
- Roles: senior manager and nominated officer
- CDD timing for sellers, buyers and auctions
- EDD, PEPs, source of funds and red flags
- Lettings at £10,000 a month or more
- SARs, training, records and review log
- Accountants & bookkeepers
AML policy and procedures for accountants
A written policy for a small accountancy, bookkeeping or tax practice, aligned with the structure of the CCAB guidance for the accountancy sector 2026.
What’s inside
- Services in scope, including off-the-shelf companies
- Client CDD before the engagement starts
- EDD, PEPs, sanctions and reliance
- Red flags from HMRC’s sector risk assessment
- SARs, training, records and review log
- All sectors · Regulation 18
Firm-wide AML risk assessment
A practice-wide risk assessment with a simple likelihood × impact scoring table and example risk factors for estate agents and accountants.
What’s inside
- Customer, geographic, service and channel risks
- Scoring table with low, medium and high bands
- Controls and residual risk for each factor
- Overall conclusion and risk appetite
- Action plan and annual review log
- All sectors · Per client
Client risk assessment form
One form per client or matter that records the CDD level you chose and why, including the enhanced due diligence triggers updated for 2026.
What’s inside
- Mandatory EDD triggers, including FATF call for action
- PEP, family member and close associate checks
- Risk factor ratings with explanations
- Source of funds and source of wealth table
- Decision, approval and review history
- All sectors · Per client
Customer due diligence (CDD) checklist
A tick-box checklist for each client covering individuals, companies and trusts, screening, ongoing monitoring and five-year record keeping.
What’s inside
- Individuals and people acting for them
- Companies: beneficial owners and PSC register
- Trusts and the Trust Registration Service
- Sanctions, PEP and adverse media screening
- Retention dates under regulation 40
These templates are a starting point to adapt, not legal advice. Check them against your AML supervisor’s current guidance before you use them. Your firm remains responsible for its own compliance.
How to use these templates
- Start with the firm-wide risk assessment. Regulation 18 requires it, and your policy must be based on the risks it identifies. Fill it in with real numbers about your clients and services.
- Adapt the policy to what you actually do. Replace every [square-bracket placeholder], delete options that do not apply and remove the guidance notes. Your supervisor will compare your day-to-day practice with what is written down.
- Get it approved and tell your staff. Senior management must approve the policy. Record who approved it and when, and keep a record of how you shared it with staff.
- Use the client forms on every file. Complete the client risk assessment and CDD checklist before you start acting, and keep them with the evidence for five years after the relationship ends.
- Review at least once a year. HMRC expects an annual review of your risk assessment and policies, and an update whenever the law, your services or your risks change.
Need sector detail first? Read our guides for estate agents, letting agents and accountants, or what changed in the Money Laundering Regulations 2026. Not sure where your gaps are? Take the 2-minute AML health check.
Template questions
Are these AML templates really free?
Yes. You can download, edit and use all five Word templates in your business at no cost, with no sign-up. They are written for small UK firms supervised under the Money Laundering Regulations 2017.
Will a template on its own satisfy my AML supervisor?
No. A template is a starting point. Regulation 18 and 19 require a risk assessment and policies that reflect your own business, and HMRC says any template must be fully adapted to your business and sector. Supervisors check that what you do day to day matches what is written down.
Do the templates reflect the 2026 changes to the Money Laundering Regulations?
Yes. They use the sterling thresholds and the narrower enhanced due diligence triggers introduced by SI 2026/621 from 30 June 2026, and HMRC’s guidance for supervised businesses as published in July 2026 and last updated on 13 October 2026. Check your supervisor’s current guidance before you use them, because guidance changes.
How often should I review my AML policy and risk assessment?
HMRC expects both to be reviewed at least once a year, even if nothing changes, and whenever your business, the law or the risks change. Record each review, who approved it and the date, and keep previous versions for at least five years.
Can I use the templates if my supervisor is a professional body?
Yes, but check your supervisor’s requirements first. Accountancy bodies follow the CCAB guidance for the accountancy sector 2026, and some publish their own pro forma documents. Legal sector firms should follow the LSAG guidance 2025.
Is this legal advice?
No. The templates are general guidance to adapt, not legal advice. Your firm remains responsible for its own compliance with the Money Laundering Regulations.
Sources
Checked on 23 October 2026.
- Money Laundering Regulations 2017 (SI 2017/692), as amended
- Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621)
- HMRC: Anti-money laundering guidance for supervised businesses (updated 13 October 2026)
- HMRC AMLG1800: Risk assessment
- HMRC AMLG1900: Policies, controls and procedures
- HMRC AMLG2200: Estate agent business guidance
- HMRC AMLG3700: Risk assessment of accountancy service providers
- CCAB: AML and counter-terrorist financing guidance for the accountancy sector 2026
- SRA: Your AML obligations (LSAG guidance 2025)
Run the ID and screening checks your policy calls for
Send your client one secure link. Start with 5 free checks, with no subscription or contract.