Many accountants and owners of accounting firms have heard the abbreviation NILLTPFN and become worried. Some decided it concerns only banks, while others feared complex requirements and inspections. In reality, the duties are arranged more logically than the alarming conversations suggest. The law makes an outsourced accountant a participant in the system for combating money laundering, but these duties are entirely doable. Let us go through it calmly and step by step: which accountants are subjects of the law and what exactly needs to be done.

This article is written for outsourced accountants, owners of accounting firms, and tax consultants in Latvia. There are no tangled legal phrases or frightening generalisations here. There are only clear explanations, concrete duties, and verified links to official sources. After reading the text to the end, the reader will know their duties exactly and will understand where the supervision focus is strengthened in 2026.

Why does this topic matter so much right now? The reason is that in the area of money laundering prevention, 2026 marks a stage of qualitative maturity of regulation and supervision. What changes is not so much the volume of requirements as the approach to checking them. Yet a precise understanding of the new emphases helps to pass an inspection calmly. That is why spending a few minutes reading today is wiser than dealing with remarks later.

It is worth removing unnecessary anxiety right away. These requirements do not mean that an accountant becomes an investigator or must suspect every client. It is about a reasonable system of checks and attentiveness to unusual operations. Most honest clients will not notice this work at all. The main thing is to build the system correctly once and keep it up to date.

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What NILLTPFN Is in Simple Terms

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First, let us deal with the abbreviation itself. NILLTPFN is an abbreviation of the law on the prevention of the laundering of criminally obtained funds and the financing of terrorism and proliferation. In simpler terms, it is a system of measures against money laundering. Its goal is to prevent criminal money from entering the legal economy through ordinary transactions.

The logic of the system is clear from a simple example. Imagine that the state builds filters on the path of dirty money. Banks, accountants, and other specialists become such filters at their own stages. Each of them checks clients and monitors suspicious operations. That is why the system works as a network in which each participant makes a contribution.

Here it is important to dispel one misconception right away. Many think these rules concern only banks and large financial institutions. But the law directly includes outsourced accountants among the subjects. That is why an accounting firm that keeps records for clients is also a participant in the system. It is not a choice but a direct duty under the law.

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Official information about the money laundering prevention system is published by the Financial Intelligence Service: fid.gov.lv

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Which Accountants Are Subjects of the Law

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This is the key question, and it is important to understand the answer precisely. The law clearly defines the range of persons to whom the duties apply. Accountants fall into this range under certain conditions. Let us examine this so that each specialist understands their situation.

The law names specific categories among the subjects. These include outsourced accountants, sworn auditors, commercial companies of sworn auditors, and tax consultants. This also includes any other person who undertakes to provide assistance in tax matters or acts as an intermediary in providing such assistance. This rule applies regardless of the frequency of providing services and the presence of remuneration.

From this follows a broad scope. The law applies not only to a classic accounting firm with a licence. It also includes tax consultants and intermediaries in providing tax assistance. That is why everyone who professionally works with other people records and taxes should check their status. In case of doubt, it is reasonable to clarify the situation with the supervisory authority.

It is important to understand which body carries out supervision. For outsourced accountants, the supervisory authority is the State Revenue Service. It is the one that checks compliance with the requirements of the law by these specialists. That is why, in case of uncertainty about the duties, it is recommended to consult the State Revenue Service. This is the officially recommended way of resolving disputed questions.

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The Main Duties of a Subject of the Law

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When the status is clear, the next question arises. What exactly must an accountant do as a subject of the law? Here there are several key duties that work together. It is useful to know them in advance in order to build the system correctly.

The first duty is to appoint a responsible person. A subject of the law is obliged to appoint a person responsible for fulfilling the requirements of the law and to notify their supervisory authority of it. The second duty is to carry out a risk assessment. A subject of the law must assess the money laundering risks in their activity. The third duty is to develop an internal control system, which is denoted by the abbreviation IKS.

The internal control system has a concrete composition. From 1 January 2022, it includes several mandatory methodologies. This is the methodology for ensuring the norms of the law on money laundering prevention. This is the methodology for ensuring the requirements of the Law on International and Latvian Sanctions. And this is the methodology for processing and protecting the data of natural persons. That is why the internal control system is not a single document but a connected set of methodologies.

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An Accountant Main Duties as a Subject of the Law

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1. Register as a person carrying out economic activity and as a subject of the law.
2. Appoint a person responsible for fulfilling the law and notify the supervisory authority of it.
3. Carry out an assessment of money laundering risks in your activity.
4. Develop and implement an internal control system.
5. Prepare a sanctions risk assessment and a sanctions internal control system.

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Client Due Diligence and Sanctions Checks

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A separate important part of the duties is working with clients. An accountant cannot simply accept any client without checking. The law requires understanding exactly who the work is being done with. That is why client due diligence becomes a mandatory stage of starting cooperation.

The essence of client due diligence is simple. You need to establish the client identity, understand the nature of their activity, and assess the risks associated with them. In complex cases, enhanced client due diligence is required. For example, special attention is paid to complex ownership structures and higher-risk operations. That is why a careful questionnaire and document check are the basis of the work.

A sanctions component is added to client due diligence. Besides assessing money laundering risks, a subject is obliged to prepare a sanctions risk assessment. It is also necessary to develop and implement a sanctions internal control system. In certain cases, a subject is obliged to report to the State Security Service, the Financial Intelligence Service, and their supervisory authority. That is why checking a client against sanctions is an integral part of the work.

From this follows a practical conclusion. A sanctions internal control system can be drawn up as a separate set of documents or built into the overall system. The main thing is that the sanctions check actually works rather than existing on paper. That is why, when setting up the system, it is worth providing for the sanctions check right away. This saves time and reduces the risk of violations.

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Where the Supervision Focus Is Strengthened in 2026

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This is perhaps the most important part for practising specialists. The supervision approach in 2026 is noticeably changing. What changes is not the list of duties itself but how their fulfilment is assessed. That is why understanding the new emphases is especially valuable right now.

The main shift concerns quality instead of quantity. The focus of supervision will be the quality of processes rather than the volume of documents. Formal reporting without sufficient analytical justification may be regarded as a weakness of the system rather than a security measure. That is why the mere presence of documents is no longer considered sufficient. It is important that the system actually corresponds to the real risk.

Concrete supervisory expectations follow from this. It is recommended to critically review the internal control system and assess whether it corresponds to the real risk rather than only to formal requirements. It is worth updating the approach to identification and verification, especially in complex structures. It is also worth re-evaluating the content of employee training, placing the emphasis on justifying decisions rather than repeating norms. That is why 2026 is the time to move from formal compliance to meaningful compliance.

Such an approach is logical in a broader context. Latvia pays great attention to the effectiveness of the money laundering prevention system. The qualitative maturity of regulation and supervision means that the state expects genuinely working systems. That is why accounting firms should prepare for inspections that look at the substance rather than the form. This is a reasonable investment in peace of mind and reputation.

It is also useful to understand the practical meaning of this shift. Previously, many firms believed it was enough to have the right document templates. Now an inspector may ask why exactly a particular client risk was assessed in a certain way. If a specialist has no clear justification, formal documents will not help. That is why the ability to explain your decisions becomes the main skill in this area.

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Reporting Suspicious Transactions

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An important part of the system is the ability to notice the unusual. An accountant not only keeps records but also pays attention to strange operations. The law expects a subject to report suspicious transactions to the relevant body. That is why understanding this duty protects a specialist from accusations of inaction.

Common sense helps to understand what is considered suspicious. These are operations that do not fit into the client usual activity or have no clear economic sense. These include inexplicably complex settlement schemes and attempts to hide the true recipient of funds. That is why it is important for an accountant to know the usual profile of their client in order to notice deviations from it.

When a suspicious transaction is detected, a clear procedure applies. A subject of the law reports it to the Financial Intelligence Service in the established manner. Importantly, the fact of the report itself usually remains confidential in relation to the client. That is why an accountant performs the role of a filter without coming into direct conflict with the client. This protects both the specialist and the system as a whole.

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Common Mistakes of Accountants

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In practice, specialists often make the same mistakes. Knowing these mistakes helps to avoid them in advance. Let us examine a few typical situations that lead to remarks during an inspection. This will help the reader not to step on the same rake.

The first mistake is a formal approach to documents. Many create an internal control system once and forget about it. But supervision in 2026 looks precisely at whether the system works in practice. That is why an outdated or template internal control system is considered a weakness. It needs to be reviewed regularly in line with the real risk.

The second mistake is weak client due diligence. Sometimes an accountant accepts a client without proper checking, especially if the client is familiar. But the law requires the same approach to everyone, regardless of personal relationships. The third mistake is ignoring training. When employees do not understand the logic of the requirements, they make mistakes during an inspection. That is why meaningful training is not a formality but protection for the whole firm.

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What an Accounting Firm Should Do Right Now

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Theory becomes useful when it turns into a concrete plan. Let us look at a simple sequence of actions for an accounting firm. This plan helps to put the system in order without haste. It suits both a small specialist and a large firm.

The first step is to check your status as a subject of the law and your registration. You need to make sure that a responsible person is appointed and notified to the supervisory authority. The second step is to critically review the internal control system for compliance with the real risk. The third step is to update the questionnaires, client due diligence, and sanctions check. This sequence removes a large part of the anxiety before an inspection.

For firms with complex clients, there is separate advice. Special attention should be paid to complex ownership structures and higher-risk operations. Since supervision looks at the quality of analysis, it is important to be able to justify each decision. And in complex or disputed cases, it is reasonable to turn to specialists in this area. Competent preparation turns the requirements of the law into a clear and manageable system.

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Frequently Asked Questions

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Is an outsourced accountant a subject of the NILLTPFN law?

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Yes, the law directly includes outsourced accountants among the subjects. This also includes tax consultants and persons who provide assistance in tax matters or act as intermediaries. This rule applies regardless of the frequency of services and the presence of remuneration. That is why an accounting firm is obliged to fulfil the requirements of the law.

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Which body supervises accountants?

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For outsourced accountants, the supervisory authority is the State Revenue Service. It is the one that checks compliance with the requirements of the law by these specialists. In case of uncertainty about the duties, it is recommended to consult the State Revenue Service. This is the officially recommended way of resolving disputed questions.

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What is included in the internal control system?

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From 1 January 2022, the internal control system includes several mandatory methodologies. These are the methodology for ensuring the norms of the money laundering prevention law, the methodology for ensuring the requirements of the Sanctions Law, and the methodology for processing and protecting the data of natural persons. That is why the internal control system is a connected set of methodologies rather than a single document.

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What does supervision pay attention to in 2026?

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In 2026, the supervision focus shifts to the quality of processes rather than the volume of documents. Formal reporting without sufficient analytical justification may be regarded as a weakness of the system. It is recommended to critically review the internal control system for compliance with the real risk. It is also worth placing the emphasis on justifying decisions in employee training.

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Does an accountant need to check clients against sanctions?

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Yes, besides assessing money laundering risks, a subject is obliged to prepare a sanctions risk assessment and implement a sanctions internal control system. In certain cases, it is necessary to report to the State Security Service, the Financial Intelligence Service, and their supervisory authority. The sanctions check can be built into the overall internal control system. The main thing is that it actually works.

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How Lex&Finance Specialists Will Help You Fulfil the Requirements of the Law

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The Lex&Finance team specialises in accounting and tax support and has worked with Russian-speaking clients in Latvia for many years. The company specialists know the current requirements of the money laundering prevention law and understand how the supervision approach is changing. That is why they help clients build a genuinely working system rather than a formal set of documents.

Lex&Finance specialists help to determine the status of a subject of the law, appoint a responsible person, and carry out a risk assessment. They help to develop an internal control system and set up client due diligence and sanctions checks in line with the real risk. In addition, the company advises on the new supervision emphases of 2026 and helps to prepare for inspections. Turning to professionals turns the complex requirements of the law into a clear and manageable system.