Regulatory update
Anti-money Laundering Guidance for the Accountancy Sector
The guidance has been approved and published, having been updated for proliferation financing and ‘ongoing’ discrepancy reporting requirements.AML guidance for insolvency practitioners
A reminder that where ICAEW is the firm’s anti-money laundering supervisor, insolvency practitioners should refer to ICAEW’s wealth of guidance and resources for current and definitive AML information.
Economic Crime Levy
The Economic Crime Levy (ECL) is an annual charge on firms who are supervised under the Money Laundering Regulations and whose UK revenue exceeds £10.2 million per year. Affected entities must register for the ECL, submit a return and pay a fee every year. Final reminder that the first payments are due by 30 September 2023.
The government has published guidance to help the firms affected understand what they must do.
Suspicious Activity Reporting
New SARs Portal
The UKFIU released its new SARs Portal for firms to submit their Suspicious Activity Reports on 18 September. Once a firm has created the new account, all SARs should be submitted via the new SARs Portal.
It is recommended that registration is completed as soon as possible as the current SARs Online System is planned to be decommissioned later this year.
There are a suite of resources to support firms with using the new portal:
- The New SAR Portal FAQs addresses frequently asked questions for organisations and individuals that submit SARs
- The New SAR Portal Overview (Guide A) provides an overview of the new SAR portal for organisations and individuals that use the portal to submit SARs
- The New SAR Portal: How to register (Guide B) provides guidance on how to register to the new SAR portal
UK Financial Intelligence Unit Resources
The UKFIU has also published new resources to support firms in improving the quality of the information they submit via suspicious activity reports:
Sanctions
Trust services
The ban on trust services to Russians came into effect on 16 December 2022. The trust services measure limits the ability of persons designated for the purpose of this measure, and persons connected with Russia, from accessing the UK’s trust services. Since March 2023, over 1,820 persons have been designated for the purposes of trust services sanctions.
Sanctions: reminder for UK persons who are overseas
No UK person (including those who are overseas) can provide sanctioned services to anyone connected with Russia. Please ensure overseas staff are compliant.
Resources
Webinar: Key report findings and support for the MLRO
Join ICAEW’s AML supervision team for this webinar which will take you through the results of two key ICAEW reports:
a) 2023 Thematic Review: The Role of the Money Laundering Reporting Officer
The results of this review seek to understand who the MLRO is and how they fulfil their responsibilities. We asked about the challenges they face, training, SAR reporting, compliance monitoring and emerging risks within their client base. We offer insight and guidance from our perspective as an AML supervisor with links to resources MLROs may find helpful.
b) 2022/23 AML Supervision Report
The results of this review seek to understand who the MLRO is and how they fulfil their responsibilities. We asked about the challenges they face, training, SAR reporting, compliance monitoring and emerging risks within their client base. We offer insight and guidance from our perspective as an AML supervisor with links to resources MLROs may find helpful.
Customer due diligence case studies
These useful CCAB case studies aim to assist the profession in keeping its knowledge of this vitally important topic up to date.
AMLbites - criminal record checks and BOOMs
This video focuses on the prohibitions and approvals of criminal record checks, BOOMs and answers FAQs.
Listen again: Firm-wide risk assessments webinar
Our anti-money laundering supervision team breaks down the components of your firm-wide risk assessment, helping you recognise and document:
- The purpose
- How the assessment impacts your customer due diligence
- Risks your business may be vulnerable to
- Risk categories
- Risk mitigations
- Live Q&A
Firm wide risk assessments Q&A
The Q&A session highlighted a range of issues. We pick out some common themes, and provide responses to key questions.
Listen back to previous AML webinars
Anti-Money laundering helpline
ICAEW members can phone in anonymously by calling +44 (0)1908 248 250 if they wish to speak to an advisor about suspected illegal activity or any matter that may trigger a need to submit a suspicious activity report.
Reminders
ICAEW will respond to the consultation in due course. We encourage our firms to reflect and submit their own view of the proposals.
Avoid losing access to your agent account
Failing to respond to an innocuous looking letter from HMRC can end up with your agent account being blocked. Find out how to avoid this trap.
