User Guide

Whole Practice Risk Assessment

Your Whole Practice Risk Assessment (WPRA) is an essential part of your anti-money laundering (AML) responsibilities. It helps you identify potential risks to your practice and guides how you manage them.

Why is this important?

Regulation 18 of the Money Laundering Regulations (MLRs) requires you to have a written risk assessment for your practice. This assessment should cover:

Information from ICB (your Supervisory Authority) on sector risks
Client risk
Services risk
Geographic risk
Transaction risk
Delivery channel risk

Your WPRA should form the foundation of your AML approach. You should review it at least once a year and update it whenever new risks arise.

Keeping Your Risk Assessment Up to Date

As part of your ICB supervision, we may ask to see your WPRA at any time. Make sure you keep previous versions for audit purposes.

You can use our ready-made template, or create your own as long as it covers the necessary areas.

Support to stay compliant

Whole Practice Risk Assessment Template

Your Whole Practice Risk Assessment (WPRA) should underpin all of your AML activity and you should review it at least annually, but with new and changing risks considered as and when they are identified.

Completing the risk assessment is a requirement of your supervision and we may ask to see it at any time. Previous versions of your risk assessment should be retained for audit purposes.

Whole Practice Risk Assessment guide

View the example

Example Whole Practice Risk Assessment

View the example

Whole Practice Risk Assessment Template

Download our the WPRA template

High Risk Clients

The Accountancy AML Supervisors Group (AASG) has flagged certain types of clients as higher risk:

Clients seeking anonymity or secrecy
Clients with a criminal history
New clients outside your usual client base
Clients who are professional advisors
Politically Exposed Persons (PEPs)
Cash-heavy businesses
Clients in high-risk industries, such as arms dealing, property transactions with unclear funding, and financial services

AASG Risk Outlook

Current AML Risks
National Risk Assessment Register
Proliferation Financing
International Risks

As your supervisory authority, we share information to assist you in carrying out your own AML risk assessments.

Read our Risk Outlook Information here.

The UK National Risk Assessment (NRA) highlights the biggest money laundering and terrorist financing risks. The latest findings suggest:

The NRA concludes that 'overall, the risk of money laundering through accountancy service providers (ASPs) remains high. The risk is highest when ASPs do not fully understand the money laundering risks and do not implement appropriate risk-based controls, particularly where ASPs fail to register with a supervisor.'

The accountancy services considered most at risk of exploitation are:

company formation and termination (TCSP services)
mainstream accounting
payroll

Since September 2022, businesses must also assess the risk of proliferation financing (funding for weapons of mass destruction). The risk for most ICB-supervised businesses is low, but if you have clients in high-risk jurisdictions (e.g., North Korea or Iran), you should document this in your WPRA.

When assessing risk, consider:

🌍 Countries with weak anti-money laundering rules

🌍 Countries with high corruption levels

🌍 Countries subject to sanctions

Templates & Guides

Keeping your WPRA up to date is key to protecting your practice and meeting your AML obligations. If your services are simple and local, your assessment may be straightforward. But if you provide higher-risk services, such as TCSP work or handling cash-heavy businesses, you must document the risks and how you plan to manage them.

Templates and guides

Useful documents

Whole Practice Risk Assessment Template

Download and complete the template

Whole Practice Risk Assessment template

Whole Practice Risk Assessment Guide

Everything you need to know to complete your WPRA

Whole Practice Risk Assessment guide

Whole Practice Risk Assessment Example

A clear example of what you need to know

Example Whole Practice Risk Assessment

Advice on Crypto Assets

MLR Risks for dealing with clients with crypto assets

Crypto Assets

Politically Exposed Persons

A politically exposed person (PEP) is an individual who is or has been entrusted with a prominent public function. Due to the nature of their position its possible for a PEP to exploit their situation for personal gain through theft, fraud, embezzlement, bribe taking along with other forms of corruption.

PEPS

Financial Sanctions

Financial sanctions are restrictions put in place by the UN, EU or UK to achieve a specific foreign policy or national security objective. All ICB members should consider whether they need to check their clients against the lists of persons/entities who are sanctioned.

Financial Sanctions

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