As we said last week the Chartered Accountants Ireland issued their AML Supervision Report for 2023/24 recently. The report covers the whole island of Ireland but in this blog, we focus on the Republic of Ireland aspects of the report.
Higher Risk Services
The report highlights the following accountancy services provided in the Republic of Ireland that are deemed to be of a higher risk from an AML perspective:
|
Service Type |
% of firms offering this service |
| Payroll services | 65.22 |
| TCSPs | 38.87 |
| Investment business | 14.89 |
| Holding clients’ money | 10.8 |
| Tax mitigation schemes | 1.39 |
| Insolvency | 1.23 |
The report focuses specifically on TCSP services provided by accountancy firms and states that ‘in Ireland, the update to the National Risk Assessment of Money Laundering and Terrorist Financing (published in 2022) rates the residual risk of money laundering for the TCSPs supervised by the accountancy bodies as Medium – High on the National Risk Assessment scale. The residual risk of terrorist financing for the TCSPs supervised by the accountancy bodies is rated as Medium – Low on the scale.
Higher Risk Clients
The report also lists the circumstances in which clients may become higher risk for AML purposes, (shown here in order of importance) according to the CAI report:
|
Client Type |
% of firms with these clients |
| High net worth individuals | 16.28 |
| Clients with cash intensive businesses | 12.68 |
| Non face to face contact | 6.63 |
| Domestic PEPs | 4.17 |
| Foreign PEPs | 2.13 |
| Higher risk jurisdiction exposure | 1.96 |
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
- Our latest CPD Webinar on The Main Changes in Irish GAAP (recorded July 2024)
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- AML Webinar (December 2023) available here, which accompanies the AML Manual. It explains the latest legal AML reporting position for accountancy firms and includes a quiz. Upon completion you receive a CPD certificate for attendance in your inbox.
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items bought together.
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
