Does the customer due diligence requirement apply to day-to-day bookkeeping?
Yes – day-to-day bookkeeping falls within the scope of the Anti-Money Laundering Act. In practice, this means the accounting firm must complete customer due diligence (CDD) before the engagement begins and carry out a risk assessment of the client. Many firms underestimate this requirement because bookkeeping is often perceived as an administrative service; legally, however, it is a qualified financial service that can be misused for illicit purposes.
This applies regardless of whether the engagement appears “simple” or involves limited contact. The legislation does not distinguish between complex advisory work and more routine services. It is therefore essential to understand when the customer due diligence obligation is triggered and which procedures must be completed before onboarding a client.
The Anti-Money Laundering Act also covers simpler engagements
The Anti-Money Laundering Act is based on a broad concept of business activities. As soon as a firm prepares, assists with or provides bookkeeping on behalf of another in the course of business, the statutory requirements apply. This holds whether the work is delivered digitally, on the client’s premises or as a fully outsourced function.
Practical examples where customer due diligence is required
- Day-to-day bookkeeping for a sole trader, partnership or limited company.
- Year-end accounts or the annual report as part of an ongoing engagement.
- Invoice processing and ledger management (accounts receivable/payable).
- Tax returns submitted to the Swedish Tax Agency (Skatteverket).
- Digital bookkeeping via third-party systems to which the firm has access.
It is not the complexity of the engagement that determines whether customer due diligence is required, but the fact that the firm provides a qualified financial service that may be used for money laundering, for example to conceal or integrate illicit funds. Accordingly, firms of all sizes need clear procedures and tailored templates that cover these steps.
A common mistake is to place routine bookkeeping clients in a general low-risk class without justification or ongoing monitoring. This can prove costly when the County Administrative Board (Länsstyrelsen) requests documentation during a supervisory review.
The Anti-Money Laundering Act also covers simpler engagements
To avoid internal interpretation issues, it is often crucial to have a clear view of the types of engagements and client situations in which customer due diligence must actually be performed. With such a framework, it becomes easier to ensure that KYC requirements are followed consistently, including for day-to-day bookkeeping and other recurring services.
The Anti-Money Laundering Act is based on a broad concept of business activities. As soon as the firm prepares, assists with or provides bookkeeping on behalf of another in the course of business, the statutory requirements apply. This holds whether the work is delivered digitally, on the client’s premises or as a fully outsourced function.
Support from an AML lawyer can streamline the work
To ensure the right judgements are made and that the requirements are met in practice, legal support is available. Our AML lawyers offer advice and reviews of existing processes tailored to accounting firms working with day-to-day bookkeeping. By building a practical, risk-based procedure, the work becomes more efficient and less vulnerable during supervision.
Does your firm need help to quality-assure customer due diligence in day-to-day bookkeeping? Contact us for a complimentary initial needs assessment – together we will ensure you meet the statutory requirements without unnecessary hassle.
