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Protecting against professional enabling: 2023/24 anti-money laundering supervision report

Our 2023/24 anti-money laundering supervision report has been published. The report provides a comprehensive account of ICAEW’s supervisory activity and continued work to protect against money laundering and other forms of financial crime within the accountancy sector.

Protecting against professional enabling

As an AML supervisor we are taking all steps necessary to prevent any of our members or firms becoming an unwitting professional enabler of money laundering, and we will remove from membership anyone who is found to be in serious breach of our regulations

Duncan Wiggetts, Chief Officer, ICAEW Professional Standards Department

Delivering effective AML supervision

We use our proactive monitoring reviews to ensure we have assessed the compliance of our entire supervised population on a risk-based cycle. This provides us with an excellent understanding of the specific areas of the money laundering regulations that firms are most likely to find challenging, as well as providing an up to date picture of AML risk for a cross-section of our firms each year.

We’ve recently refocused our monitoring methodology away from technical compliance to examine the effectiveness of firms’ policies and procedures.

We use a range of supervisory tools and methods to assess the compliance of our supervised population, and the effectiveness of the policies and procedures they have put in place.

Michelle Giddings, Head of AML, ICAEW Professional Standards Department

Key findings from our supervisory activity

Our updated monitoring methodology that focuses more on the three stages of customer due diligence (CDD) has identified that the least effectively performed stage is verification procedures. Often this is because the verification procedures designed have not effectively mitigated the identified risks.

The most commonly occurring area of non-compliance is ongoing monitoring with 36.7% of non-compliant firms found to have ineffective ongoing CDD. This is an important area of the money laundering regulations – firms must regularly update their CDD and we provide help and guidance in this report.

Read the report

Read the 2023/24 AML supervision report to find out the results of our quality assurance monitoring activity.

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