Anti-Money Laundering
Money-laundering offences, oversight, risk-based controls, CDD, suspicious activity reporting and records.
How to study the ATT Qualification
Use Finance Act 2025 for the 2026 tax papers, complete the three foundational CBEs early, apply professional ethics throughout and concentrate option practice on the one paper you will enter.
Core concepts
Concept 1
Tax practitioners must understand money laundering, supervision and their firm's risk-based obligations.
Exam cue: Identify client, beneficial owner, service and risk factors.
Concept 2
Customer due diligence identifies and verifies clients and beneficial owners according to risk.
Exam cue: Select proportionate CDD and ongoing monitoring.
Concept 3
Suspicion may require internal and external reporting while avoiding tipping off.
Exam cue: Escalate suspicion through the correct reporting route without alerting the subject.
Risk pitfalls and guardrails
Treating long-standing clients as exempt from due diligence.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Confusing proof of identity with the whole CDD process.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Discussing a suspicious activity report with the client.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Memory anchors
Risk-based
Assess client, geography, service, delivery and transaction risks.
CDD
Identify and verify client and beneficial owner and understand purpose.
Ongoing monitoring
Keep knowledge and transactions under review.
Suspicion
Report internally and follow the authorised SAR process.
No tipping off
Do not disclose information that could prejudice an investigation.
Checkpoint rule
Do the check-up only after you can summarize each concept in one sentence and identify one dangerous pitfall from memory.
Knowledge Check (after reading)
Short check-up to confirm understanding of this module.
Check-up Questions
What is “criminal property” for UK money-laundering purposes in broad terms?
A new corporate client has a layered ownership chain. What CDD outcome is essential?
Answer all questions to submit.
Next step personalized recommendations
Continue learning
Move forward only after this module is stable.
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