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AML client reviews: how often accountants should refresh customer due diligence

What the Money Laundering Regulations require on ongoing monitoring, how to set a risk-based review cycle for each client, the triggers that mean a review is due early, and how to evidence it for your supervisor.

3 min readUpdated 13 October 2026By the Deadlio team

Anti-money laundering compliance is one of the areas supervisors look at most closely when they visit accountancy practices. A common finding is not that due diligence was never done, but that it was done once, at the start of the relationship, and never updated.

What the rules require

Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, accountants must:

The Regulations do not set a fixed review period. Your supervisor – such as ICAEW, ACCA, AAT or HMRC – expects you to set one in your policies according to risk, and to follow it.

Setting a risk-based cycle

Many practices use a pattern like this:

Client risk ratingTypical review frequency
HighEvery year
MediumEvery 2 years
LowEvery 3 years

Whatever pattern you choose, write it into your AML policy and apply it consistently.

Triggers for an early review

A review should also happen whenever something material changes, for example:

What a review should cover

  1. Confirm identity details are still current, including beneficial owners.
  2. Refresh the client risk assessment and record the reasoning.
  3. Check sanctions and politically exposed person (PEP) status.
  4. Update your understanding of the source of funds where relevant.
  5. Record the date and outcome, so you can evidence the review to your supervisor.

Tracking reviews in Deadlio

In Deadlio, each client has an AML / CDD card with the Last AML / CDD review date and an AML review cycle in years. Leave the cycle blank to use your practice default, set in Account. The Overview counts clients with no AML review recorded, and the client list flags reviews that are overdue. After a review, Mark done records today’s date and starts the next cycle.

See every overdue AML review in one click. Start your free 30-day Deadlio trial.

This guide is general information for accountancy practices and is not legal advice. Follow your own AML supervisor’s guidance. Last reviewed October 2026.

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