Third Party agreement for CDD and AML

Hattie Registered Posts: 1
I am a sole trader bookkeeper. AATQB - Very small scale. I only take on work through one accountant and have previously relied on them to carry out the due diligence on new clients. This agreement has been in place verbally for many years.

Following from a practice review, the AAT have said that this agreement has to be in writing, but they do not have a template that I can base it on (they only have a 13 page subcontractor agreement but I bill the customers direct so this does not really apply and has loads in it that I don't think applies). They have also said it must include text about anti money laundering regulations section 37(?) and its all gone a bit over my head!

Just wondered if any self employed book keepers that use the forum have such an agreement in place with any accountants that they work with or do you all carry out your own checks? If you do our own checks, who do you use? If anyone has such a 3rd party agreement in place I would be very grateful if you could point me in the direction of any template that you used. I am rather stressed with it and don't want to get it wrong or I understand that they could take disciplinary action.

Many thanks


  • Neillaw
    Neillaw Registered Posts: 307 Dedicated contributor 🦉
    Sorry - not sure on the set up for AATQB as to your money laundering requirements.
    If your providing the service direct to the client and being paid by the client then you should already have a money laundering structure in place together with connection to a monitoring body such as AAT/HMRC.
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