Free sanctions check of clients for accounting firms: AML duties and how to screen the whole client list

Short answer: accounting firms can check their whole client list against sanctions lists for free with Unicorn Intelligence: a free test of all clients uploaded from a CSV or Excel file or read from QuickBooks, Xero or Sage, against the OFAC, EU, UK, UN and other official lists, plus a free check of a single name without sign-up. This matters because in the UK, Canada and France accountants and tax advisers are subject to anti-money laundering (AML) rules that require client due diligence, and in every jurisdiction they must not provide services to, or handle funds for, sanctioned persons.

Key definitions

AML obligations: duties under anti-money laundering law, such as identifying clients and beneficial owners, assessing risk and reporting suspicions.

Client due diligence (CDD): identifying and verifying the client and its beneficial owners and understanding the purpose of the relationship.

Sanctions screening: checking clients against official sanctions lists. It is separate from AML: sanctions prohibitions apply to everyone, not only to regulated firms.

What the law says, country by country

Sources checked on 5 November 2026.

The US point: liability without knowledge

Under US sanctions, OFAC can impose civil penalties even when a firm did not know that a client was listed. Knowledge, wilfulness and the quality of the compliance programme are factors that change the amount, as described in the OFAC Enforcement Guidelines, not conditions for liability. This is why a documented screening process matters for any firm with US persons, US dollar flows or US clients.

Step by step: screening your client base

1. Export your client list from your practice management, accounting or CRM software, with company names, countries and registration numbers.
2. Add beneficial owners and directors, because a company owned 50% or more by a listed person can be blocked.
3. Screen against the official lists: OFAC, EU, UK Sanctions List and UN.
4. Add PEP and adverse media checks for higher-risk clients, as part of your AML risk assessment.
5. Rescreen the whole base every time the lists change, not only at onboarding.
6. Document each check and the reasoning on each possible match in the client file.
7. Escalate genuine matches to your money laundering reporting officer or legal adviser before doing further work.

Practical checklist for firms

• Written firm-wide risk assessment that covers sanctions as well as money laundering.
• Screening of every new client and its owners before the engagement letter.
• Daily rescreening of existing clients.
• Clear rule: no payments, no transfers and no client money movements for a listed party.
• Record of every check kept for the period your rules require.
• Staff training on false positives and on what to do with a real match.

How to automate it

Unicorn Intelligence connects read-only to QuickBooks, Xero, Sage and major CRMs, imports your clients in one click and checks all of them every day against the official sanctions lists, PEP and insolvency sources and adverse media. It is an informational tool: legal decisions and obligations remain the firm's.

Informative content: decisions and legal obligations remain yours.