Assessing the international and domestic risks of money laundering
ACCA to conduct AML risk assessment.
The 2017 UK anti-money laundering regulations state that each supervisory authority must identify and assess the international and domestic risks of money laundering and terrorist financing to which those relevant persons for which it is the supervisory authority are subject. This will assist the supervisory authority to focus its efforts on the higher risk areas.
To meet this regulatory requirement, during the coming weeks ACCA will be asking all its supervised firms to complete a risk questionnaire to obtain the necessary information.
The risk assessment will help us identify the areas of your business that pose a greater risk of money laundering and will enable ACCA to determine the risk profile of your firm.
The questionnaire will be sent to the contact person for each ACCA supervised firm and it is very important that the information provided is complete and accurate to ensure a fair assessment. Firms that do not complete the questionnaire within the established timescales may be classified as high risk and subject to an accelerated AML supervisory visit.
Section 4 of the CCAB anti-money laundering guidance for the accountancy sector highlights that businesses are required to analyse the money laundering or terrorist financing (MLTF) risks they face and make proportionate responses to them. It also requires those who supervise to assess the risk analysis the business has undertaken.
It is important to remember that the guidance is built on a proportionate risk-based approach. As the guidance states, the ‘risk-based approach requires evidence-based decision-making to better target risks. No procedure will ever detect and prevent all MLTF, but a realistic analysis of actual risks enables a business to concentrate the greatest resources on the greatest threats.’
A sole practitioner undertaking accounts preparation work with locally based clients who they meet face to face will have a different risk profile and policy from a large firm undertaking international tax work, holding client monies within client accounts and not meeting clients face to face.