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AML – the essentials, issue 24

In this issue, we summarise the resources issued in response to UK sanctions against Russia, highlight the implications of the Economic Crime Act and look at the risks associated with virtual assets in the seventh instalment of AML: The Basics.

In this issue, we summarise the resources issued in response to UK sanctions against Russia, highlight the implications of the Economic Crime Act and look at the risks associated with virtual assets in the seventh instalment of AML: The Basics.

Sanctions:

CCAB Russia sanctions guidance

The Consultative Committee of Accountancy Bodies has issued joint guidance for the profession on the situation in Ukraine.

Sanctions FAQ

New AMLbites video: Sanctions

Sanctions risk – changes in client behaviours

New SARs Glossary Code

The NCA has issued a new SAR glossary code for reporters to use to identify SARs relating to sanctions.

How to check your client base

Reputational risk – Russian sanctions

ICAEW members are urged to be hypervigilant of any connections with Russia among their clients and perform careful due diligence in the light of Russian sanctions.

Watch OFSI’s recent webinar briefing on UK sanctions relating to Russia

A recording of the event has now been published on gov.uk on can be accessed. We strongly encourage you to watch this webinar to understand how sanctions may affect you and your clients.

OFSI licence guidance

When a person or organisation is subject to an asset freeze, any funds or economic resources belonging to them, must be frozen. You must not deal with these assets, or make them available to, or for the benefit of, a designated person unless there is an exception in the legislation you can rely on, or you have a valid licence.

Regulatory updates

Companies House reform white paper published

A legal overhaul of the register will bolster the powers of Companies House so that it can better tackle crime and fraud and provide a stronger foundation for boosting enterprise.

EDD requirements: Update to high risk third countries list – UAE now included

The amended list came into force on 29 March 2022. Enhanced due diligence (EDD) is required for all business relationships and transactions with a person, or entity, established in a high risk third country.

Economic Crime Act

The Economic Crime (Transparency and Enforcement) Act 2022 came into force on 15 March. It establishes a new Register of Overseas Entities Beneficial Ownership to help law enforcement track down those using UK property as a money laundering vehicle, or those in breach of financial sanctions. There is heightened AML risk that individuals may approach ICAEW AML-supervised firms to assist them in restructuring the ownership of their assets to avoid the register and/or financial sanctions.

ICAEW AML-supervised firms should assess the risk that their firm may be used to facilitate money laundering, and update their firm-wide risk assessments and mitigating actions accordingly.

AML risk

AML: How money launderers use virtual assets

In the seventh instalment of Anti-Money Laundering: The Basics, IFAC and ICAEW look at the risks associated with virtual assets

COVID-support fraud: staying vigilant on the frontline

Fraudsters have been targeting COVID-19 business support schemes since their inception. For firms preparing end of year accounts, staying alert to COVID-related fraud is more important than ever.

Guidance on CDD required for law firms

This guidance is designed to supplement the requirements within the CCAB AML Guidance for the Accountancy Sector.

AML resources

Anti-money laundering helpline

ICAEW members can phone anonymously if they wish to speak to an adviser about suspected illegal activity or any matter that may trigger a need to submit a suspicious activity report.

Disciplinary update: March 2022

Read about recent cases where we have taken disciplinary action against ICAEW member firms and ICAEW members for AML matters. 

UKFIU SARs In Action magazine

Raise an AML concern

ICAEW Economic Crime hub

Client screening service

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