Most AML tools UK accountants use were originally built for solicitors and adapted afterwards. They handle the ID check well; the accountancy-specific workflow (MLR 2017 client risk assessment, ICAEW or ACCA inspection evidence, MLRO oversight, ongoing monitoring tied to the practice's client lifecycle) was bolted on. We build the workflow around the ID check rather than the other way round.
The most common misconception in scoping conversations is that AML software is mainly about running an ID check on a new client. The ID check is a small part. The bigger picture: firm-wide written risk assessment, per-client risk scoring, ongoing monitoring, MLRO oversight, and the evidence trail that survives an ICAEW or ACCA inspection.
MLR 2017 (as amended through 2024 and 2025 statutory instruments) requires every UK accountancy practice to:
ICAEW DPB-licensed firms have an additional supervisory layer including a specific risk-scoring methodology and inspection checklist. ACCA firms have their own MLRO requirements. AAT and CIOT each have their frameworks. HMRC supervises the firms that fall outside the professional bodies.
Almost every UK accountancy practice carries the same artefact: a CDD log workbook, sometimes a single sheet, sometimes multi-tab, alongside whichever ID-check supplier the firm uses. It is what the inspector sees first when they ask "show me your AML evidence." The columns:
The workbook breaks predictably. The risk-scoring methodology lives in a separate Word document nobody consults. When a client's risk profile changes mid-year (new beneficial owner, news event triggering EDD), updating the workbook is a manual step that often does not happen. The "next review due" column generates no alerts. When the inspector asks "show me the SAR consideration for this case," the trail goes from workbook to email inbox to a file note that may or may not exist.
The fix is not a better ID check supplier; most do the check well. The fix is software around the check that handles risk assessment, ongoing monitoring, MLRO workflow, and evidence trail, in the format the supervisor wants to see.
These are illustrative shapes drawn from UK accountancy workflow patterns. The fixed-quote bands are the real ranges we quote for builds of this shape; the workflows described are the patterns that fit each context.
Profile: ICAEW DPB-licensed sole principal with around 90 active clients and 50 new onboardings/year. Uses SmartSearch (£6 basic, £18 enhanced) and a Word risk-assessment template filled in by hand. Each onboarding typically takes 45 to 60 minutes of the principal's time on AML alone, and the firm-wide risk assessment tends to drift out of date between inspection cycles. The shape that fits: a focused AML workflow on SmartSearch's API. Client risk assessment auto-populated, EDD auto-triggered, MLRO sign-off dashboard, annual firm-wide risk reminder. Typical band: £7,000 to £12,000 fixed quote, five to seven weeks. Expected outcome: roughly 30 minutes saved per onboarding and the inspection-failure tail risk removed.
Profile: ICAEW-supervised, sole MLRO (one of the partners), around 350 active clients. Uses Veriphy (£4.50 basic) plus the CDD workbook. Typical pain: MLRO is the bottleneck because every CDD requires sign-off, and juniors do not consistently update the workbook; inspection outcomes risk "satisfactory with conditions" with 60 to 80 hours of partner remediation time. The shape that fits: CDD workflow with risk-based MLRO escalation (around 70% low-risk auto-approve with digest, 30% with EDD triggers route to MLRO), ongoing monitoring alerts, audit trail in ICAEW format, training records. Typical band: £15,000 to £20,000 fixed quote, eight to twelve weeks. Expected outcome: MLRO time on AML drops from around 6 hours/week to around 2.
Profile: ACCA-supervised, part-time MLRO, around 1,200 active clients. Uses Credas plus SharePoint for evidence. Typical pain: approaching the threshold for in-person ACCA inspection; partners are not confident the evidence trail would survive. Ongoing monitoring is the known gap, the practice can show initial CDD but cannot evidence that risk reviews actually happened at committed cadence. The shape that fits: a full AML platform with risk-scoring engine, EDD workflow, ongoing monitoring with triggered reviews, MLRO dashboard, SAR drafting assistant, training records, plus a "show the inspector" report in ACCA format. Typical band: £20,000 to £28,000 fixed quote, twelve to sixteen weeks. Expected outcome: replaces around 12 hours/week of manual practice manager and MLRO time, closes the inspection tail risk.
Shared pattern: at each scale, the off-the-shelf ID check is fine. The wrap-around (risk assessment, ongoing monitoring, MLRO workflow, evidence trail) is where the practice has bolted Excel onto the SaaS or paid for an additional SaaS that does not fit. The custom build closes both gaps.
Most practices are well-served by one of the off-the-shelf platforms below. Custom only makes sense at certain scales and shapes.
| Option | Typical cost | What it does well | Where it does not fit |
|---|---|---|---|
| SmartSearch | £600 to £4,000/yr + per-check fees | Mature ID and verification, AML/PEP/sanctions screening, well-known by ICAEW inspectors | Risk-assessment workflow is generic; accountancy-specific reporting is light |
| Veriphy | From ~£3 per check + subscription tiers | Solid ID checks, strong client portal experience, good price point | Workflow built primarily for solicitors and conveyancers, accountancy fit is partial |
| Credas | £600 to £3,500/yr | Mobile-first ID capture, biometric verification, neat client experience | Wrap-around evidence trail for inspection is light; risk assessment is on you |
| AMLBot | Pay-per-check, ~£3 to £15 | Crypto-focused, good for clients with crypto exposure, automated monitoring | Less mature for traditional accountancy CDD, weaker ICAEW reporting |
| Onfido (now Entrust) | Mid-market enterprise pricing, ~£8 to £30 per check | World-class ID document validation, biometric, strong AI on document authenticity | Priced and built for larger fintech and regulated finance; overkill for small practice |
| Built-in AML in Karbon, Senta, TaxDome | Bundled with practice management subscription | Convenient if you already use the practice management tool | Light functionality, mostly a workflow trigger rather than a full AML system |
| Custom AML system (this category) | £8,000 to £25,000 fixed build + pass-through check costs | 200+ onboardings/year, ICAEW or ACCA inspection due, EDD-heavy client base, MLRO bottleneck, dissatisfaction with the off-the-shelf wrap-around | Sub-100 onboardings/year where a SmartSearch plus Word template combo is genuinely fine |
A custom build typically integrates one of the above as the ID-check supplier under the hood, so the practice keeps the check quality and gains the workflow. The supplier choice is rarely the technical blocker; bring the supplier you already use or want to use, and we wire it in.
"Build it all in-house including the ID check." ID-check suppliers do verified ID, document authenticity and biometric better than any custom build at a reasonable price. The economics of running a million-document training set are theirs to absorb. The work worth doing in-house is the workflow around the check, not the check itself.
"Adopt the cheapest tool and rely on the firm-wide risk assessment Word doc." The cheapest tools are fine for the check. The Word doc is exactly the artefact that fails at inspection: it gets stale, the inspector cannot evidence it was applied to specific files, and the EDD trigger logic is not enforced. Saving £500/year on the tool is the cost of the inspection failure: a published disciplinary listing, a conditional licence, remediation work and partner time absorbed for months. The all-in cost commonly runs well into five figures for a small firm even before the fine itself.
"Wait for our practice management tool to release proper AML." Karbon, Senta and TaxDome are all shipping AML features. None at the depth a regulated practice needs. The bundled features are convenient triggers, not full AML systems. If AML is the genuine gap, addressing it directly is years faster than the bundled roadmap.
Real bands. Every project scoped and fixed-quoted before work starts. ID-check supplier costs pass through at supplier rates; you keep the commercial relationship.
| What it is | Timeline | Fixed quote |
|---|---|---|
| Scoping (written delivery plan, scope, fixed quote, no commitment to proceed) | 1 to 2 weeks | £1,500 to £3,500 |
| Focused AML workflow on top of SmartSearch / Credas / etc. (sole practitioner to 5 staff) | 4 to 8 weeks | £8,000 to £15,000 |
| Full AML platform for SME firm (5 to 20 staff, MLRO dashboard, ongoing monitoring, ICAEW or ACCA evidence) | 8 to 14 weeks | £15,000 to £25,000 |
| AML built into a broader practice management replacement (with onboarding portal, CRM, document handling) | 16 to 24 weeks | £25,000 to £55,000 |
| Tech partnership (we run, maintain, improve, including regulatory updates) | Monthly, no lock-in | £450 to £1,500 / month |
The strategic question: what would a "satisfactory with conditions" outcome cost in partner time, remediation and PII implications? Most partners have a number in mind. A fixed build in the £15,000 to £20,000 band pays back at the first inspection the system carries cleanly. Adjacent: AI implementation, CRM for UK accountants (the workflow this AML slots into), and the tech partnership retainer for ongoing regulatory updates.
I am Oliver Wakefield-Smith. More than twenty years building software for regulated industries: satellite communications (Ofcom), UK broadcast (BBC), water utilities (Ofwat), industrial engineering with safety-critical components. Regulated software is mostly evidence-trail discipline, exactly what an AML system needs.
The team that builds is a directed team of AI agents. Senior judgement on what to build, how to scope, and how to evidence the outcome stays with twenty years of human experience. AML domain knowledge (MLR 2017, ICAEW DPB, ACCA, supervisor checklists) is well-documented and learnable. We build the system you own outright, then either step away or stay on as your tech partner.
Adjacent: our take on where AI earns its place in a business and the broader custom app build shape.
Accountancy practices in the UK are supervised under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), as updated through 2025 secondary regulations. ICAEW DPB-licensed firms, ACCA, AAT and CIOT firms each have their own supervisory frameworks layered on top. The core obligations are written firm-wide risk assessment, written client risk assessment for each engagement, customer due diligence (CDD) including ID and verification, enhanced due diligence (EDD) for higher-risk clients, ongoing monitoring, MLRO appointment, suspicious activity reporting (SAR) to the NCA, and record-keeping for five years post-relationship end.
Off-the-shelf AML platforms run £600 to £6,000 per year for an SME practice depending on user count and check volume. Per-check pricing typically sits at £3 to £8 for a basic ID check, £8 to £25 for enhanced PEP and sanctions, £20 to £80 for full verified ID with document validation. A custom AML system built specifically for an accountancy practice's workflow runs £8,000 to £25,000 as a fixed-quote build, plus pass-through ID-check costs at supplier rates. The custom build makes sense at 200+ client onboardings/year where the off-the-shelf per-user pricing has crossed the breakeven point.
Direct fine costs are often modest but the tail is worse. ICAEW's 2024/25 AML Supervision Report shows 41 firms fined a combined £197,706 across the year, with individual fines ranging from £240 to £31,700. HMRC's accountancy-sector enforcement averages a few thousand pounds per fine, mostly for unregistered trading, though larger fines do occur. The harder cost is usually not the fine itself but the conditional licence (the firm has a defined period to remediate, with re-inspection), the public listing in the regulator's disciplinary record, the PII implications at renewal, and the senior time absorbed by the remediation programme. For a small firm, the all-in cost of a failed inspection including remediation, lost client work and partner distraction commonly runs well into five figures. Confirm specific obligations with your supervisor.
SmartSearch, Veriphy, Credas, AMLBot and Onfido are excellent at the check itself: ID document validation, PEP screening, sanctions screening, biometric verification. They were primarily built for solicitors and conveyancers, and the accountancy workflow has been adapted onto them. A custom build keeps using the best-in-class check supplier under the hood (via API) and wraps the accountancy-specific workflow around it: written firm-wide risk assessment integration, MLR 2017 client risk scoring with the actual accountancy risk factors, ICAEW or ACCA checklist evidence, ongoing monitoring tied to your client lifecycle, SAR drafting, MLRO dashboard, and full audit trail in the format your supervisor inspects.
Yes, because what the inspector wants is evidence that the firm has applied the regulations consistently. The supervisor does not require a particular software vendor. The evidence trail is what matters: written risk assessments, dated CDD records, EDD triggers and approvals, SAR considerations, MLRO oversight, training records, record-keeping discipline. A custom system can produce that evidence trail in exactly the format the supervisor asks for, which is often cleaner than the off-the-shelf vendors who produce evidence in their own format and require some manual reformatting at inspection time.
Yes. Code, workflow, risk-scoring rules, audit trail format, all of it runs on your own environment, owned outright. The ID-check supplier (SmartSearch, Credas, Onfido) is a pass-through integration; you keep the commercial relationship directly. If we part ways the system keeps running, and another developer can pick it up.
Tell us your supervisor, your size, your current setup. We will tell you honestly whether a custom build is the right answer or whether tightening up the off-the-shelf tool would do the job. No charge for the conversation.
Email oliver@digitalsignet.com