We asked the money laundering reporting officer (MLRO) at a sample of 100 high and high/medium risk accountancy firms a series of questions. We also asked for a copy of their most recent firm-wide risk assessment. ICAEW’s Quality Assurance Department reviewed the responses and our summarised findings are included in this report – alongside our key reflections – we recommend firms pay particular attention to these insights.
What are firms doing well?
The majority of firms had completed a firm-wide risk assessment. We have noted that this percentage has increased year on year, since the requirement was first introduced in 2017. This indicates that our firms are reflecting more carefully on money laundering risks and considering the mitigations. It enhances our profession’s defences, protecting us against the risk of being used as professional enablers by those seeking to legitimise and launder the proceeds of crime.
The firm-wide risk assessment is a good opportunity to reflect and to challenge your own view of your client base.”