Case study: Begbies Traynor Group
Anne Austin
Director
Supporting a multi-entity accountancy and advisory group Begbies Traynor with AML & ICAEW-compliance reviews
At Enderley Consulting, we have long supported law firms with independent AML audits and regulatory guidance. Recently, we were instructed by a large, multi-entity accountancy and advisory group to carry out a full-scope review of their anti-money laundering (AML) compliance. This project required a deep understanding not only of the Money Laundering Regulations 2017 (MLR 17) but also of ICAEW regulatory requirements and the governance structures typical of publicly listed or FCA-regulated entities.
This instruction leveraged Enderley Consulting’s core strengths: practical regulatory expertise, thorough risk assessment, and a collaborative approach that respects complex multi-entity governance frameworks. The project was led by our director Ed Austin, supported by AML specialist Valerie Dickson, who brought her extensive experience in financial-crime compliance, policy development, and internal audit to guide the group through the review.
The challenge
The group operates across multiple entities, business lines, and jurisdictions, including advisory, insolvency, and accountancy services. As you would expect with firms like Begbies Traynor, it is subject to multiple layers of governance:
- Corporate governance: Oversight by the board of directors and adherence to public company principles (for listed entities) ensures transparency, risk management, and ethical standards.
- Professional regulation: Individual practitioners are governed by bodies such as the ICAEW, which sets standards for insolvency, accountancy, and financial reporting activities.
- FCA oversight: Certain activities, including regulated financial advice or structured products, are subject to FCA rules.
- Statutory compliance: Insolvency, restructuring, and corporate advisory work must comply with UK statutory frameworks.
The client required assurance that their AML controls, internal governance, and firm-wide risk assessments were robust, consistent, and aligned with these regulatory expectations. They also sought independent verification of operational adherence to AML policies, staff training effectiveness, and internal reporting processes.
Our approach
Our work centred around five key activities as follows
- Document review
We examined all key AML documentation across the group, including the Regulation 18 group-wide risk assessment and any entity-specific assessments. We reviewed Regulation 19 AML policies and procedures, Client Matter Review processes, and internal governance structures, including reporting lines to the board and escalation routes for suspicious activity.
Internal communications, record-keeping processes, and the most recent internal AML compliance review were also assessed. This comprehensive review concluded with a gap analysis benchmarking the group against MLR 17 and ICAEW requirements, reflecting the multi-layered regulatory environment in which they operate.
- Interviews across the organisation
We conducted interviews remotely and in person with the MLRO, senior leaders, compliance personnel, and a representative sample of employees and contractors across the group. These discussions gave us a great insight into the practical application of AML procedures, cultural understanding of regulatory obligations, and operational challenges, allowing us to evaluate both compliance and internal governance effectiveness.
- File audits
We reviewed a representative sample of client files to assess the quality and consistency of due diligence, risk assessment, source-of-funds checks, ongoing monitoring, and red-flag escalation. This process identified operational variations that were not evident from documentation alone, helping to ensure regulatory compliance across multiple entities and functions.
- Review of training
Enderley Consulting assessed the content, relevance, and delivery of AML training across the group to ensure it was representative of current regulations. We considered the frequency of training, staff comprehension, and alignment with ICAEW and MLR 17 expectations. This review highlighted strengths and opportunities to enhance engagement and ensure consistent application of AML practices.
- Completed ICAEW-Aligned Checklist & Report
Our final deliverables included a detailed report and an ICAEW-aligned checklist providing a clear benchmark against regulatory expectations. We provided a prioritised action plan and tailored recommendations to strengthen governance, monitoring, record-keeping, and training. Throughout the engagement, we maintained clear and practical communication, helping the group navigate complex regulatory requirements confidently.
The result?
The group benefits from a clearly defined AML governance framework, stronger consistency across their teams, and enhanced training aligned to real-world risk. They have a clear roadmap for addressing gaps, reinforcing internal controls, and maintaining compliance with MLR 17 and ICAEW requirements. The organisation valued the clarity and depth of the review, as well as Enderley Consulting’s collaborative, practical approach, which balanced regulatory rigor with operational realities.
By delivering this review in a multi-regulated, complex environment – similar to publicly listed or FCA-regulated professional services groups – Enderley Consulting confirmed its ability to provide independent, authoritative AML and compliance support beyond the legal sector, extending into accountancy and other regulated industries.
Why this matters now
With the government’s recent decision to delegate all AML and counter‑terrorism financing supervision for legal, accountancy and other professional services to the FCA, firms across the sector are preparing for a major shift in regulatory oversight.
In this transitioning regulatory landscape, Enderley Consulting is uniquely positioned to support law firms, accountancy and advisory firms through the transition – thanks to our proven experience in delivering ICAEW‑aligned AML audits, dual‑regime compliance reviews, and governance assessments in complex, multi‑entity environments. Because we operate independently and do not belong to a statutory supervisory body, we can provide impartial, expert guidance tailored to the emerging expectations of the FCA. This, combined with Valerie Dickson’s weighty experience in supporting large banks and accountancy practices, puts our clients one step ahead — ensuring their AML policies, systems, and governance frameworks are robust and adaptable even before the new supervisory regime is implemented.
Expanding our support to accountancy and FCA-regulated firms
This engagement demonstrates that Enderley Consulting’s AML and regulatory expertise extends well beyond law firms. We support accountancy practices, insolvency specialists, and other FCA-regulated entities with:
- Independent AML audits and firm-wide risk assessments
- Policy review and governance advice
- Training evaluation and improvement
- File audits and operational compliance assessments
- ICAEW-aligned reporting and prioritised action plans
If your firm is seeking independent AML assurance or guidance on strengthening compliance frameworks in complex, regulated environments, Enderley Consulting can provide practical, tailored support.
What our client had to say
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