Sample · ACCA return sheet · a fictitious practice

The ACCA return sheet, filled in.

This is the sheet the AML return pack builds from the interview: ACCA’s 2026/27 AML annual return, question by question in the form’s own order and wording, with the practice’s answer in the form’s own band. In the product each answer has a Copy button; you check each one and file the return yourself, in ACCA’s own portal.

Harwood & Lane Accountants Ltd — a fictitious practice. Answers as at 3 November 2026.

The practice

Practice: Harwood & Lane Accountants Ltd, a fictitious practice
Address: 4 Tanners Yard, Leicester LE1 9ZZ (invented)
Supervisor: ACCA
MLRO: Priya Harwood
Signed: The firm-wide risk assessment and the AML policies, controls and procedures, signed and adopted by Priya Harwood (Principal and MLRO) on 3 November 2026. Where the signed document shows a control is in place, its row says so.

54 rows, in the form’s order

4 of the form’s 58 questions are follow-ups that do not apply to this practice (it answered No to the question before), so, as in the product, they are not shown. The interview decides every one of the rows below, so none is marked “Not held”; where it does not, the sheet says “Not held” and why, and never guesses.

1. Who is your AML Professional Body Supervisor?
The practice’s answer
ACCA
2. ACCA Firm Registration Number:
The practice’s answer
DEMO-0147
3. Has the firm been trading for more than 12 months?
The practice’s answer
Yes
4. MLRO Name:
The practice’s answer
Priya Harwood
5. MLRO Email Address:
The practice’s answer
priya.harwood@harwoodlane.example
6. MLRO Phone Number:
The practice’s answer
07700 900124
7. Are you the Money Laundering Reporting Officer (MLRO) of the Firm?
The practice’s answer
Yes
8. Does the firm have any Beneficial Owners, Officers and Managers (BOOMs) that are not ACCA Practising Certificate Holders?
The practice’s answer
No
9. How many additional partners/directors/employees/sub-contractors does your firm have? (Note: this includes both full and part-time.)
The practice’s answer
1-5
10. What was the firm’s total revenue for the last financial year? (Please round to the nearest £)
The practice’s answer
£250,001 - £632,000
11. Has the firm held any client's money or managed securities or other assets on behalf of clients in the past two years?
The practice’s answer
Yes
12. What was/is the main reason for holding client money, securities or other assets?
The practice’s answer
HMRC refunds
13. Approximately how many clients has the firm provided payroll services to in the past two years?
The practice’s answer
26 - 50
14. Does the firm provide a registered office address for its clients?
The practice’s answer
Yes
15. Approximately how many clients has the firm provided their registered office address to as a service in the past two years?
The practice’s answer
11 - 25
16. Does the firm offer trust formation services?
The practice’s answer
No
17. Does the firm arrange or act as director/secretary for any of its clients?
The practice’s answer
No
18. Does the firm act as a trustee for any of its clients?
The practice’s answer
No
19. Does the firm offer company formation services?
The practice’s answer
Yes
20. Approximately how many clients has the firm provided company formation services to in the past two years?
The practice’s answer
1 - 10
21. How many clients has the firm provided services to in the past 12 months?
The practice’s answer
101 - 250
22. Cash-based businesses (e.g., Takeaways, Retail shops, Scrap metal dealers, Car Wash, Nail bars, Massage parlours, etc)
The practice’s answer
11 - 25
23. High-value dealers (e.g., Jewellers, Car dealership, Art, Antiques and Luxury items, etc)
The practice’s answer
0
24. Properties (including estate agents, property developers and private landlords; this should include buying/selling and renting of properties)
The practice’s answer
1 - 10
25. Import and export (including haulage, freights and shipping)
The practice’s answer
0
26. Money Service Businesses (e.g., money remittance, bureau de change, cheque converters, etc)
The practice’s answer
0
27. Cryptocurrency (e.g., clients in which a significant proportion of the assets they hold and transact with are crypto assets)
The practice’s answer
0
28. Visa and immigration services
The practice’s answer
0
29. Investment services
The practice’s answer
0
30. Charities
The practice’s answer
0
31. Precious metals (e.g., gold or diamond trading)
The practice’s answer
0
32. 'Wealthy individuals' (HMRC defines individuals as ‘wealthy’ if they have incomes of £200,000 or more, or assets equal to or above £2 million in any of the last 3 years.)
The practice’s answer
1 - 10
33. Client with annual revenue in excess of £10 million
The practice’s answer
0
34. Politically Exposed Person (including by association)
The practice’s answer
0
35. How many of the firm’s clients represent more than 15% of the firm’s total revenue?
The practice’s answer
0
36. Does the firm have any existing clients that have been convicted of a financial-related crime or appear in a sanctions list?
The practice’s answer
No
37. How many of your existing clients predominately reside or are based outside of the UK?
The practice’s answer
1 - 10
38. How many of the firm's existing clients have associations with HM Treasury Advisory Notice: High Risk Third Countries?
The practice’s answer
0
39. How many Suspicious Activity Reports have you filed to the NCA in the past two years? (This includes Defence Against Money Laundering requests.)
The practice’s answer
1-5
40. How many internal Suspicious Activity Reports by employees have been formally escalated to the MLRO and documented in the past two years?
The practice’s answer
1-5
41. A Suspicious Activity Report must be submitted via the NCA online portal. Have you registered with the new updated NCA SAR online system available from 18 September 2023?
The practice’s answer
Yes
42. What information, evidence and documentation do you typically obtain and check when onboarding a new client? Select all that apply.
The practice’s answer
Proof of identification (such as passport or photo driving license)
Proof of address
Company Structure
Check PSC Register (i.e., Companies House Records)
Use electronic verification
43. How frequently does the firm conduct ongoing monitoring of clients?
The practice’s answer
6 - 12 Months
44. Does the firm categorise clients according to their level of risk? (For example, Low, Medium or High) (Technical Factsheet)
The practice’s answer
Yes
45. Approximately how many clients do you classify as high-risk?
The practice’s answer
1% - 5%
46. Approximately how many clients do you classify as low-risk?
The practice’s answer
51% - 99%
47. As the MLRO, have you conducted and documented a firm-wide risk assessment? (Technical Factsheet)
The practice’s answer
Yes - and it is updated on a periodic basis
48. Does the firm have documented AML policies and procedures in place? (Technical Factsheet)
The practice’s answer
Yes - and it is updated on a periodic basis
49. As the MLRO, have you conducted and documented a proliferation financing risk assessment? (Technical Factsheet)
The practice’s answer
Yes - I have conducted it once
From your signed document, signed 3 November 2026.
50. As the MLRO, have you produced a written report on the operation and effectiveness of the firm's AML systems and controls? (Technical factsheet)
The practice’s answer
No
51. As the MLRO, have you completed formal AML training within the past two years? (Please note, we do not consider reading articles or publications to be formal AML training.) (Technical Factsheet)
The practice’s answer
Yes
52. Have you provided AML training to all relevant employees? (Please note: we do not consider employees reviewing the firm's AML policies and procedures or receiving 'on-the-job' training to be sufficient AML training.)
The practice’s answer
Yes - conducted periodically or regularly
53. Does the firm have a formal process for employees to report suspicious activity to the MLRO? (For example, employees completing an internal suspicious activity report form.)
The practice’s answer
Yes
54. Does the firm conduct and document an independent assessment of its AML controls? (Please note: independent does not necessarily mean external. For example, a partner, director, or senior individual who is not the MLRO may conduct the assessment.)
The practice’s answer
No
You marked this not applicable in the interview

Source: ACCA, 2026/27 Anti-Money Laundering (AML) Annual Return — UK (ACCA’s published form, PDF). This sample shows the ratified wording; your own sheet is written from your answers. PracticeGuard does not file the return for you.

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