Before any billable work
MLR 2017 obligations apply before you perform accounting or tax services. Identity verification, beneficial ownership understanding, purpose and nature of the relationship, ongoing monitoring — these are not year-end admin tasks.
Firms get caught when AML lives in a folder on the partner's desktop while staff already started bookkeeping in the job system.
A sequence that sticks
Step one: client details and CH match. Step two: risk assessment documented. Step three: ID and address evidence collected and linked to the client record. Step four: engagement letter signed. Step five: services activated in your practice system.
When AML is a tab in onboarding — not a separate checklist — completion rates rise and file reviews take minutes, not archaeology.
Ongoing monitoring
Set review triggers: change of directors, unusual portal upload patterns, new high-risk service lines. Your practice platform should surface client events from CH and portal activity, not rely on someone remembering to check.
Run your practice from one command centre
Clients, Companies House onboarding, deadlines, document vault and client portal — full platform on every plan.
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