Regulatory update
AASG Risk Outlook (updated July 2024)
This Risk Outlook sets out the key AML risks within the accountancy sector. It was produced by the Accountancy AML Supervisors Group (AASG). You should review the risks within the Risk Outlook and consider how your firm may face these risks. July 2024 updates include the addition of risks and red flags around proliferation financing and crypto-assets, as well as further details on the risk of trust and company services.
Updated High Risk Third Countries list
Enhanced due diligence (EDD) is mandatory for clients based in high risk third countries (or for any transactions involving them). FATF has announced that Turkey and Jamaica no longer require increased monitoring. Venezuela and Monaco have been added to its list of jurisdictions requiring increased monitoring and have also been added to the UK list of high risk third countries. Check the current list to make sure you are carrying out EDD when it is required.
Companies House: proposed ID verification explained
Proposed amendments to the Companies Act 2006 introduce stringent identity verification for those setting up, running or controlling companies, in a bid to stamp out money laundering via fake identities.
The role of the money laundering reporting officer (MLRO)
New MLRO Guidebook
A comprehensive guide for new and existing money laundering reporting officers, nominated officers and AML compliance officers. Read the section that corresponds with your role for full guidance on your responsibilities and to help you break the role down into manageable tasks.
UK Financial Intelligence Unit Resources
The UKFIU publishes resources to support firms in improving the quality of the information they submit via suspicious activity reports. Here are the latest publications:
Reminders
Raise an AML concern
Raise your concern confidentially if you believe an ICAEW supervised firm is breaching the Money Laundering Regulations 2017.
Criminal checks
Under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, ICAEW must approve all beneficial owners, officers and managers (BOOMs) in our supervised firms. ICAEW can only approve a BOOM if that individual has no relevant unspent criminal convictions. We therefore require all BOOMs to obtain criminal record checks.
Amendment to AML regulations – domestic PEPs
Read the changes of a Statutory Instrument which came into force on 10 January 2024. The instrument puts into legislation that a domestic politically exposed person (PEP) has a lower starting point for risk than a foreign PEP and, if no enhanced risk factors are present, the extent of customer due diligence for a domestic PEP should be lower than a foreign PEP.
Suspicious activity reporting
The legacy SAR Online System has now closed. Should you need to submit a SAR, users must register for the new portal, which should now be used as your firm’s sole reporting route. The National Crime Agency has also provided additional registration and SAR submission guidance.
Resources
Watch: Customer due diligence in practice
Our panel of money laundering reporting officers provided practical insight into how they face the challenges of effective and compliant customer due diligence.
Customer due diligence in practice webinar: Q&A
During ICAEW’s recent anti-money laundering (AML) webinar on customer due diligence (CDD) in practice, viewers highlighted a range of issues. We pick out some common themes, and ICAEW’s AML team provides responses to key questions.
AMLbites
Stay ahead of the curve with our short and engaging anti-money laundering bitesize videos.
The latest video is: Financial sanctions (updated July 2024)
