ICAEW AML publications
ICAEW thematic review: the firm-wide risk assessment
The firm-wide risk assessment is the focus of this year’s thematic review. We contacted the money laundering reporting officer (MLRO) at a sample of 100 high and high/medium risk accountancy firms. We asked the MLROs a series of questions and for a copy of their most recently completed firm-wide risk assessment. Our Quality Assurance Department reviewed the responses, and the findings are included in this report alongside our key reflections.
AML Supervision Report 2024/2025: Protecting against professional enabling
Read the results of our supervisory activity, the most common findings from our monitoring reviews and access the latest recommended resources and guidance.
Webinar invitation: 2024 AML results and thematic review: the firm-wide risk assessment
Listen to ICAEW’s anti-money laundering supervisory team discuss both of these recently published reports.
Regulatory update
Accountancy AML Supervisors Group Risk Bulletins
Access our new archive of AML Risk Bulletins to check you haven’t missed any alerts.
Access is restricted to money laundering reporting officers and compliance principals, and cannot be extended more widely (This restricted access is a condition of our permission from the AASG to share the bulletins with our firms.)
Log in or reset your password using your record number as the username.
Reminder of Current High Risk Third Countries
During the last update, Venezuela and Monaco were added by the Financial Action Task Force to the list of jurisdictions requiring increased monitoring and have been added to the UK list of high risk third countries. Turkey and Jamaica no longer require increased monitoring.
Cross-system professional enablers strategy
Read about the National Economic Crime Centre’s strategy to galvanise a whole system response to deliver a step-change in reducing the threat posed by professional enablers.
Strengthening the UK’s implementation and enforcement of trade sanctions
The Office of Trade Sanctions Implementation (OTSI), part of the Department for Business and Trade, was launched in October 2024. Its purpose is to strengthen the United Kingdom’s implementation and enforcement of trade sanctions, including those in relation to audit, accountancy and tax services. OTSI says it will work with industry to make complying with sanctions obligations as straightforward as possible. OTSI will have powers to publish information about sanctions breaches and impose civil monetary penalties.
Corporate reform: Companies House timeline
Companies House has published its intended implementation timeline for the Economic Crime and Corporate Transparency Act 2023. The timeline shows how more measures will be introduced under the act over the next few years – including ID verification and registering to be an Authorised Corporate Service Provider.
Companies House will give you plenty of notice before you need to take action. Timelines are dependent on secondary legislation and will be kept under review.
There will be key moments on the implementation timeline that are important to you. So, it’s important that you start to prepare by keeping your registered email address up to date and making sure your emails are monitored.
The timeline includes changes planned through until 2026 but we have included the most imminent changes below:
By autumn 2024
Companies House should be able to:
- issue financial penalties for any relevant offences under the new Act and the Companies Act
By winter 2024 into 2025
Companies House should be able to:
- expedite the striking off of companies where the registrar has concluded the company has been formed for a false basis
- annotate the register in a wider range of circumstances, such as when a company has a director who has been disqualified but has yet to terminate their appointment on the register, or where Companies House has issued a statutory notice to require more information from a person, but the matter remains unresolved
You can also keep up to date by visiting the Changes to UK company law website. This is regularly updated with new information.
Suspicious Activity Reporting
UKFIU resources
The UKFIU has also published new resources to support firms in improving the quality of the information they submit via suspicious activity reports. Read its latest publications:
Reminders and recently published resources
AASG Risk Outlook
Review the risks within the Risk Outlook and consider how your firm may face these risks. July 2024 updates included 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.
Webinar recording: 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.
Webinar recording: Practice Assurance monitoring report
Watch our Quality Assurance Department present the key findings from monitoring reviews over the last year, including a focus on anti-money laundering themes.
AMLbites
Stay ahead of the curve with our short and engaging anti-money laundering bite size videos. Recent topics include the AASG Risk Outlook, financial sanctions and politically exposed persons.
Guide to the role of money laundering reporting officer
Comprehensive guidance for new and existing money laundering reporting officers (MLROs) to enable you to fulfil your role effectively and break it down into manageable tasks. Select the role that applies to you for full guidance on your responsibilities.
Contact us
Anti-money laundering helpline
Raise a concern if you believe a firm supervised by ICAEW is breaching money laundering regulations
