Introduction
According to the FIAU (2024), total suspicious reports filed have increased over the years; however, the percentage of total reports submitted by accountants still amounts to less than 1%. This underlines both the challenges and the opportunities for accountants to strengthen their role as gatekeepers, ensuring that financial systems remain transparent and resilient. The following points can serve as a practical guide for accountants to improve these numbers and enhance their contribution in the fight against financial crime.
The First Line of Defence
As trusted professionals with direct access to clients’ financial records, accountants are often the first line of defence against suspicious transactions (Turner, 2022). Their proximity to day-to-day operations places them in a unique position to identify early warning signs of potential money laundering (Ringgaard et al., 2025). By reviewing transactions, reconciling accounts, and ensuring the legitimacy of financial flows, accountants play a vital role in maintaining the integrity of the financial system (Dashkevich et al., 2024). Unlike automated systems, accountants can apply professional judgement and contextual understanding to detect unusual activity (Fomina et al., 2022).
Importance of Analysing Invoices
An accountant usually manages a large portfolio of clients, many of whom share the same filing deadlines (Wolfe and Sterna, 2020). Wolfe and Sterna (2020) also noted that accountants, faced with the pressure to meet these deadlines, easily fall into a routine, inputting invoices mechanically without taking the time to assess their content. This “robotic” approach, while efficient in the short term, can lead to critical oversights (Afriyie et al., 2023). Invoices may contain subtle red flags, such as inconsistent supplier details (Wynn, 2021), unusual payment amounts (Daniels, 2024), or transactions that do not align with the client’s usual business activity (Saxena, 2024). By taking a moment to analyse the information carefully, accountants can identify irregularities that may otherwise go unnoticed and prevent potentially suspicious transactions from being processed unquestioned.
Question Suspicious Transactions
While careful analysis of invoices is vital, it is equally important to go a step further and apply critical thinking to what those invoices represent. Critical thinking is an essential skill for every accountant, particularly when assessing the legitimacy of transactions (Terblanche and De Clercq, 2021). Jeppesen (2019) argues that beyond simply recording figures, an accountant should actively question the rationale behind each invoice or payment, asking, “Does this invoice make sense?”
This mindset encourages professionals to look beyond surface details and consider whether the transaction aligns with the client’s normal business activities, scale of operations, and financial behaviour (de Sousa Carvalho, 2025). By applying analytical reasoning rather than relying solely on compliance checklists, accountants are better equipped to detect patterns that may suggest manipulation, concealment, or fraudulent intent (Kranacher and Riley, 2019). Ultimately, this reasoning allows accountants to identify potential red flags early and take timely action before suspicious activity escalates.
Know Your Client
Building on the importance of analysing invoices and questioning unusual transactions, it becomes clear that these efforts are only effective when the accountant truly understands their client (Yigitbasioglu et al., 2023). To accurately identify suspicious activity, an accountant must first be familiar with the client’s business model, operational nature, target markets, and financial objectives (Ali et al., 2024). The authors continue to argue that this knowledge provides valuable context when assessing whether a transaction or invoice aligns with the client’s legitimate business activity. Without this understanding, even obvious red flags can go unnoticed or be misinterpreted. An accountant’s role should not be limited to data inputting; it is equally vital to build a professional relationship with the client (Turner et al., 2020). Regular communication fosters trust, provides better insight into the client’s operations, and allows the accountant to identify anomalies that may indicate potential money laundering or other financial misconduct (Cherry, 2018).
Stay Knowledgeable
An accountant does not only need to keep abreast of changes in accounting standards, tax laws, and industry-specific regulations; it is equally vital to stay informed about emerging trends in how criminals attempt to launder illicit funds (Levi and Soudijn, 2020). Money laundering techniques evolve continuously, often adapting to new technologies, business models, and regulatory loopholes (Khan et al., 2025). By keeping up to date with typologies issued by financial intelligence units, law enforcement, and professional bodies, accountants can better recognise red flags and unusual transaction patterns in their clients’ records (Kratcoski, 2018). Regular participation in training sessions, AML seminars, and professional workshops strengthens both technical competence and awareness (Shonhadji and Maulidi, 2021). Ultimately, staying knowledgeable ensures that accountants remain proactive in detecting suspicious behaviour rather than reacting to it after the fact.
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Article written by
Mr Kurt Callus, Intelligence Analyst, within the FIAU Malta’s Intelligence Analysis team.