A timely reminder of the minimum requirements for all ACCA-supervised firms.
To comply with anti-money laundering (AML) regulations, and to help prevent your firm from unwittingly facilitating the proceeds of crime, all ACCA supervised firms are reminded that at a minimum they must do the following:
conduct and document on a periodic basis a firm-wide risk assessment of the Money Laundering and Terrorist Financing (MLTF) risks faced by the firm
establish and regularly update AML policies and procedures specific to the firm – considering the risks and mitigation identified within the firm’s firm-wide risk assessment
conduct the appropriate level of due diligence on every client including risk rating the client appropriately, identifying and verifying the client, understanding their source of funds and conducting appropriate levels of ongoing monitoring
provide adequate AML training on a periodic basis for all relevant employees. The training provided should cover an explanation of the law, explanation of what money laundering is, ‘red flags’, Suspicious Activity Reporting (SAR), tipping off and failure to report suspicious activity.
have a formal process for employees to document and escalate suspicious activity to the money-laundering reporting officer (MLRO).
The above applies to all firms regardless of size.
To support members in meeting their AML obligations, ACCA has produced guidance on all the above and more, which can be found here. This includes practical factsheets on SARs, client risk assessment and due diligence procedures, as well as the latest draft guidance for the accountancy sector from CCAB.
As indicated in this recent article on AccountingWeb, HMRC has been warning accountants about fines they may face for AML regulation failings. Following the above guidance issued by ACCA will assist members in ensuring they are compliant with the regulations.