BSA/AML Compliance for Accounting Firms: What Managing Partners Must Do Now

Banks are watching accounting firms more closely when it comes to Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) compliance. If your firm handles trust accounting, outsourced CFO work, or international tax planning, you are already on the radar.

Why This Matters for CPAs

BSA requirements center on recordkeeping, customer due diligence, and reporting suspicious transactions. For accounting firms: know who your clients really are (beneficial ownership), understand how their money flows, and have documented policies for escalating high-risk work.

Action Steps for Managing Partners

Standardize client onboarding. Create a formal intake checklist covering beneficial ownership, transaction patterns, key jurisdictions, and banking relationships.

Define BSA/AML risk triggers. Document red-flag scenarios such as opaque entities, unusual wire patterns, or sudden changes in payment flows, and how your firm will escalate or refuse such engagements.

Train technical staff and partners. Engagement teams must understand when to ask for more information and when to involve management before proceeding on complex structures.

Keep governance and workpapers aligned. Maintain clear meeting minutes, engagement letters, and workpapers that show how higher-risk arrangements were reviewed and approved at the partner level.

Bottom Line

BSA/AML compliance is not just a banking problem. If your firm handles client funds, complex structures, or cross-border cash flows, regulators expect strong internal controls and clear documentation. Treat BSA/AML readiness as an extension of your existing quality control practices.

Source: Ledger Lowdown research team, March 28, 2026