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MLRO annual report template for accountancy firms

Check once a year that your AML controls work, report what you found to the people who run the firm and record what they decided. This MLRO annual report template is one Word document: a review checklist, a client file sample, the MLRO report and a decision page.

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What the report looks like

MLRO annual report template
What the report coversPart of the report
The review period and who completed it
✓
HeadingStart and end dates, the MLRO's name and the date, and who receives the report
Risk assessment and policy reviewed
✓
Part 1: checklistReviewed in the last 12 months, approved, changes recorded and staff told
Changes of MLRO or compliance officer
✓
Part 1: checklistSupervisor told within 14 days
Client checks
✓
Part 1: checklistCDD before work started, a rating with a reason for every client, enhanced checks for High clients and PEPs, and no overdue reviews
Companies House register checks
✓
Part 1: checklistExcerpts on file and differences reported
Internal reports and NCA reports
✓
Part 1: checklistEvery report logged and decided with reasons, and NCA reports made promptly
Training, screening and records
✓
Part 1: checklistStaff trained and screened, owners and managers approved, and CDD records kept five years then deleted
A sample of client files
✓
Part 2: client file sampleFive files, including at least one High risk client and one new client, with any issues found
The year in figures
✓
Part 3: MLRO reportInternal reports, NCA reports, requests for a defence against money laundering and discrepancy reports
Weaknesses and recommendations
✓
Part 3: MLRO reportChanges in the law or guidance, the main weaknesses found and what the MLRO recommends
What the firm decided
✓
Part 4: decisionActions, who does each and by when, signed for the partners, directors or owner

When you need it

The Money Laundering Regulations 2017 require firms to review their policies, controls and procedures regularly and keep a written record. The accountancy sector's guidance says the MLRO should report to the board, or the partners or owner, at least once a year in writing on how well those controls work. The board should be able to show it considered the report and acted on it.

  • Your firm's AML year ends and the yearly review is due
  • Your supervisor has asked for evidence of your last review, or a monitoring visit is coming up
  • A new MLRO takes over and wants a clear picture of where the firm stands
  • The law or your supervisor's guidance has changed, as it did on 30 June 2026

How to use the MLRO annual report template

  1. Set the review period. Fill in the start and end dates, the MLRO's name and who will receive the report.
  2. Work through the checklist. Answer each line, and write the finding and the action needed wherever the answer is No.
  3. Check a sample of files. Pick at least five, including one High risk client and one new client, and note what is missing.
  4. Write the MLRO report. Add the year's figures from the MLRO log, the changes in the law and the main weaknesses, then your recommendations.
  5. Get the decision signed. The partners, directors or owner agree the actions, who does each and by when, and sign Part 4.

Questions

Does an MLRO have to write an annual report?

The accountancy sector's guidance says the MLRO should report to the board, or equivalent, at least once a year, and that this should be a written report. The regulations also require you to review your controls regularly and keep a written record.

What should an MLRO annual report include?

An assessment of how well the firm's AML controls work: the review findings, a sample of client files, the number of internal and NCA reports, changes in the law, the main weaknesses and the MLRO's recommendations. It ends with the actions the firm agrees.

Who does the MLRO report to?

The board or equivalent managing body. In a small practice that is the partners, the directors or the owner. They decide what action to take and sign the decision in Part 4.

Does a sole practitioner need an MLRO annual report?

A sole practitioner with no staff and no associates doesn't have to appoint an MLRO. The duty to review your controls regularly and keep a written record still applies, and the checklist and file sample work as that record.

How long should the annual report be kept?

Keep it with the firm's AML records. It shows your supervisor that the firm reviewed its controls and acted on what it found.

Also in the AML compliance pack

Firm-wide risk assessmentAML policy and proceduresClient risk registerCustomer due diligence form: individualsCustomer due diligence form: companies and LLPsInternal suspicion reportMLRO logAppointment of MLRO and compliance officerTraining and screening record

See the whole pack →

Who it's for

MLROs at sole practices and small accountancy firms who need a yearly review their supervisor can see.

Last checked

Checked against the Money Laundering Regulations as amended on 30 June 2026 and the sector's July 2026 guidance.