Why Accounting Professionals are exposed to financial crime risk and how to respond with confidence
Accounting Professionals play a critical role in the integrity of the financial system. They advise on corporate structures, manage financial records, facilitate transactions and in many cases, act as trusted intermediaries between clients and the broader economy.
That position of trust also creates risk.
Globally, regulators and law enforcement agencies have repeatedly highlighted the misuse of accounting services by organised criminal networks seeking to launder illicit proceeds, finance terrorism or obscure links to sanctioned entities and proliferation activity. As a result, expectations on accounting professionals are rising as more jurisdictions move to formally capture Accounting professionals under AML/CTF regimes.
A robust, defensible ML/TF/PF risk assessment is no longer optional. It is the foundation on which every other compliance obligation rests.
Why Accounting Professionals are vulnerable to exploitation by organised criminal networks
Accounting Professionals are not targeted because they are careless, they are targeted because they are effective.
Criminal networks actively seek out professional intermediaries who can provide legitimacy, credibility and technical expertise. Accounting firms are especially attractive because they sit at the intersection of finance, governance and advisory services.
Key vulnerabilities include:
- Professional trust and credibility – Accountants are assumed to operate within legal and ethical boundaries. When criminal activity is channelled through an accounting firm, transactions can appear legitimate by default reducing scrutiny from banks, counterparties and authorities.
- Expertise in financial and corporate structures – From trusts and partnerships to complex corporate arrangements, accountants understand how to design and maintain structures that can obscure beneficial ownership, layer transactions or create distance between illicit funds and their true source.
- Control over financial records and reporting – Financial statements, tax filings, invoices and reconciliations can be manipulated to disguise the origin, movement or purpose of funds, sometimes without overt red flags if risks are not properly assessed.
- Intermediary and advisory roles – Accountants frequently act as introducers, administrators or advisers across multiple service providers. This intermediary role can be exploited to move funds or assets across institutions and jurisdictions.
In short, even well-intentioned Accounting Professionals can be drawn into financial crime exposure if risks are not clearly identified, assessed and actively managed.
The typical ML/TF/PF risks faced by Accounting Professionals
The risk profile of an accounting firm is shaped by what it does, who it serves, and where and how services are delivered. Common ML/TF/PF risk exposures include:
Misuse of Professional Services
- Formation and management of shell companies or complex ownership structures
- Trust and corporate services used to conceal beneficial ownership
- Preparation or certification of financial records that misrepresent economic reality
- Use of false invoices, sham expenses or circular transactions
Client and Engagement Risk
- Clients operating in cash-intensive, high-risk or lightly regulated industries
- Politically exposed persons (PEPs) or clients with opaque ownership structures
- Clients linked to high-risk or sanctioned jurisdictions
Transaction and Funds-Handling Risk
- Handling or movement of client funds through trust or escrow accounts
- Large or unusual transactions inconsistent with client profiles
- Cross-border flows without clear economic rationale
Proliferation and Sanctions Exposure
- Clients involved in trade, logistics, manufacturing or dual-use goods
- Transactions involving sanctioned jurisdictions or counterparties
- Weak screening of counterparties, UBOs or source of funds
These risks rarely exist in isolation. They intersect and without a structured assessment, they can compound unnoticed.
What Accounting Professionals must consider when conducting financial crime risk assessments
A credible ML/TF/PF risk assessment is not a static document or an annual compliance exercise. It is a living risk intelligence process that informs decisions, controls and governance.
At a minimum, Accounting Professionals should ensure their financial crime risk assessments:
Are enterprise-wide and proportionate
Enterprise-wide ML/TF/PF risk assessments must reflect the full scope of services, clients, delivery channels and jurisdictions – scaled appropriately to the firm’s size and complexity.
Identify inherent risk clearly
This includes understanding where and how the firm could be exposed to ML/TF/PF risk before controls are applied.
Assess control effectiveness
Policies alone are insufficient. Firms must assess whether controls are appropriately designed and operating effectively in practice.
Produce defensible, auditable outcomes
Regulators increasingly expect clear documentation, rationale for risk ratings, evidence of governance oversight and traceability from risks to controls and mitigation actions.
Remain current
Risk environments change. New typologies, geopolitical developments and regulatory reforms require regular review and refresh of risk assessments.
Spreadsheets and static documents struggle to meet these expectations, particularly as regulatory scrutiny increases.
Arctic Intelligence’s ML/TF/PF risk and control module for Accounting professionals
To address these challenges, Arctic Intelligence provides a purpose-built ML/TF/PF Risk and Control Module designed specifically for accounting and professional services firms.
The module delivers pre-built, regulator-aligned content across the full risk assessment lifecycle while remaining fully tailorable to reflect each firm’s services, risk appetite and jurisdictional obligations.
Who does this module apply to?
The money laundering, terrorism and proliferation financing risk and control module contains a library of risks, controls and control tests designed specifically for different types of Accounting Professionals:
- Bookkeepers
- Certified Public Accountants
- Chartered Accountants
- Tax Consultants and Tax Advisers
- Insolvency and Restructuring Practitioners
- Trust and Company Service Providers
What does this module contain?
Enterprise-wide ML/TF/PF risk assessment, covering the following risk groups:
- Environmental Risk – covering exposure to internal and external risk indicators.
- Customer Risk – covering customer base profile, customer location risk, legal form risk, industry / occupation risk, PEP risk and customer activity risk.
- Industry Red Flag Risk – covering ML/TF/PF red flags associated with Accounting Professionals.
- Product and Services Risk – covering the services provided by Accounting Professionals that are subject to AML/CTF laws and the inherent risk characteristics of each of these.
- Channel Risk – covering face-to-face and non-face-to-face customer onboarding and transaction channels.
- Transaction Risk – covering higher risk transaction types.
- Country Risk – covering higher risk country risk exposures based on the residency, nationality or citizenship (Individuals) and country of registration, incorporation, domicile or operations (Entities).
Also included is a comprehensive library of suggested controls and control tests relevant to accounting firms and professionals to support the design and operational effectiveness testing of controls.
Firms can deploy the content module out-of-the-box or tailor it to their methodology, eliminating the need to start from scratch while maintaining full ownership of their risk model.
From regulatory obligation to strategic risk insight
Accounting Professionals are expected to demonstrate that their ML/TF/PF risks are understood, governed and actively managed.
By combining structured methodology with pre-built, tailorable content, accounting firms can move beyond compliance as paperwork and build a defensible, intelligence-driven risk framework that protects the firm, its clients and the financial system.
Here are some of the companies we’ve helped in this sector:
| Grant Thornton | MYOB | Parsons Roddick & Co |
Get started with Arctic Intelligence
Whether you are establishing your first enterprise-wide ML/TF/PF risk assessment or upgrading a legacy spreadsheet-based program, Arctic Intelligence’s Accounting Professionals Risk and Control Module is a scalable, defendable and configurable solution that meets the needs of modern compliance teams.
Book a demo or contact us to explore how our platform can help your business strengthen compliance, mitigate financial crime risk and build a risk program that stands up to regulatory scrutiny.
Or visit our website to learn more.
