The term AML (Anti-Money Laundering) often terrifies accountants and tax advisors unnecessarily. Many mistakenly believe it only applies when a client transfers hundreds of millions. The reality is quite different. As an independent accountant or tax advisor, you very often meet the definition of an obliged entity.
Table of contents
1. AML for Accountants: When do you become an obliged entity?
The law does not distinguish whether you are a large consulting firm or a freelance accountant. If you participate in setting up companies, managing trusts, providing registered offices, or acting as a partner, you are an obliged entity.
This also includes processing tax returns or managing standard accounting. The accounting profession is often the first point of contact for emerging companies, making you a gateway into the financial system, and therefore you must have a created system of internal AML principles.
2. What the AML Act for 2026 says
The AML Act places several clear obligations on accountants. From 2026, this primarily includes rigorous client identification and retaining data for a specified period.
- Client Identification and Control (KYC).
- Determination of the Ultimate Beneficial Owner (UBO) and checking for PEPs (Politically Exposed Persons).
- Regular AML training and evaluating the client's risk profile.
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3. AML Questionnaire Template for Accountants
“Where can I find an AML questionnaire template for accountants?” This is the most common question we receive. Unfortunately, there is no universal state-mandated template – each advisory profession has its specifics, and the questionnaire must cover your concrete risks.
A proper AML form for accountants must contain ID details, the definition of the client relationship, the source of wealth, and a declaration clause. Instead of sending PDF files, you can transition this entire AML form into a digital format with automated extraction.
4. Registration with the Financial Analytical Office (FAU)
Another highly searched topic is the “FAU form for AML registration of an obliged entity”. Since 2025, many professions – including external accountants – are required to undergo AML registration specifically with the FAU.
You should ideally register within 60 days of acting as an obliged entity. Make sure you also have your System of Internal Principles (SVZ) in order, which the FAU can randomly inspect.