Not all clients carry the same AML risk. The UK National Risk Assessment, FATF typologies, and supervisor sectoral risk assessments converge on a recurring shortlist of sectors that warrant elevated scrutiny. The seven below are the ones most often flagged in published HMRC and ICAEW guidance, with notes on what specifically to look for in each.
1. Property and real estate
Property has been a top-three concern in every UK National Risk Assessment since 2017. The combination of high transaction values, the ability to layer ownership through corporate vehicles, and the ease of integrating illicit funds through legitimate property purchases makes the sector a perennial target.
For accountancy clients, the risk shows up in clients with rapidly accumulating property portfolios disproportionate to declared income, frequent refinancing without obvious purpose, or properties held through opaque overseas vehicles. Source of funds enquiries on every material acquisition are essential.
2. Money service businesses
MSBs - money transmitters, currency exchangers, cheque cashers - are inherently exposed to laundering risk because their core service is moving value. Many are well-run and properly supervised. Many are not. UK MSBs are themselves regulated, but accountancy firms acting for MSB clients sit one step removed from that supervision and must do their own enhanced scrutiny.
EDD on MSB clients typically involves confirming their own AML supervision status, reviewing transaction monitoring evidence at audit, and being alert to volumes inconsistent with declared business size.
3. High-value dealers (art, jewellery, vehicles, watches)
Dealers in goods who accept cash payments of €10,000 (or equivalent) or more fall within scope of MLR 2017 themselves. Where the accountancy firm takes them on as a client, the risk pattern centres on the use of high-value movable assets as a vehicle for storing or transferring illicit value.
Common red flags: sudden cash deposits matching wholesale purchases, frequent transactions just below recordable thresholds (structuring), and customer bases concentrated in higher-risk jurisdictions.
4. Trust and company service providers (TCSPs)
Firms that form companies, provide registered offices, act as nominee directors or shareholders, or administer trusts present elevated risk both as clients and as referral sources. The FATF has repeatedly flagged TCSPs as a vector for shell-company abuse, and the UK's National Risk Assessment ranks them similarly.
Accountancy firms acting for TCSP clients should expect to apply EDD as a default and to scrutinise the ultimate beneficial owners of the structures the TCSP manages, not just the TCSP itself.
5. Cryptoasset businesses
Cryptoasset exchange providers and custodian wallet providers operating in the UK are AML-supervised by the FCA. As a sector, cryptoassets feature prominently in laundering typologies because of pseudonymity, cross-border transfer speed, and the proliferation of mixing services.
For accountants acting for crypto clients - exchanges, miners, traders, or holders - EDD should include source-of-wealth scrutiny that goes beyond the on-chain trail, sanctions screening of counterparty wallet patterns where possible, and clear documentation of the client's own AML controls if they are themselves a regulated cryptoasset firm.
6. Cash-intensive small business sectors
Hospitality, beauty services, car washes, taxi operators, and similar cash-intensive sectors are not inherently criminal - most operators are entirely legitimate. They are higher-risk because cash receipts make turnover difficult to verify and create natural cover for the integration of illicit funds.
EDD here typically means examining declared turnover against operating capacity (covers per night, chair hours per week, vehicle utilisation), and applying scepticism to capital injections that exceed plausible accumulated profit.
7. International trade and shipping
Trade-based money laundering - manipulated invoicing, phantom shipments, over- or under-invoicing - has been a growing focus for FATF and the JMLSG. Clients with material cross-border trade flows, especially involving high-risk jurisdictions or commodities such as gold, scrap metal, or fuel, sit firmly in the EDD bracket.
Practical EDD steps include cross-checking shipping documentation against invoice values, reviewing customs declarations where available, and being alert to repeated transactions with related parties at inconsistent pricing.
How to operationalise the list
Encode the seven sectors as risk-factor tags in your practice management system. When a new client is onboarded into one of these sectors, the system should auto-flag EDD as required, route the file to the MLRO for review, and surface it on the Compliance Radar with an annual refresh cadence. Accupe's client profile holds the sector tag and the risk rating against the same record, which removes the chance that a sector trigger gets noted in onboarding but lost by the time the periodic review falls due.
Sector risk is not destiny
A client in a high-risk sector is not by definition a problem client. The vast majority of property investors, restaurateurs, and crypto traders are entirely legitimate. The sector flag is a prompt to apply more scrutiny, document more thoroughly, and refresh more frequently - not to decline the relationship. Many of the most profitable client relationships in UK practice sit inside these seven sectors.
Closing
Maintain the list, train the team on it, embed it in your risk-rating logic, and review the firm's exposure across the seven sectors annually as part of the firm-wide risk assessment refresh. A practice that knows exactly where its sectoral concentration sits is a practice that can defend its EDD calls at the next supervision visit without breaking a sweat.