The Consultative Committee of Accountancy Bodies (CCAB) in the UK has issued two new guides entitled ‘Accountants and Counter-Terrorist Financing and ‘Staying Safe within The Money Laundering Regulations’ for its accountant members.
These latest updates act as a useful reminder of some 13 essential steps that every accounting entity and Money Laundering Reporting Officer (MLRO) should already be implementing.
It is worth re-visiting these essential steps now. The guide states that you should:
1. Know your client and their business;
2. Appoint a MLRO and train your staff as to their obligations (as part of the training, the staff need to complete some form of assessment to prove they have understood the training);
3. Record and monitor details of the client’s identity;
4. Monitor money laundering identity evidence and report to the MLRO and
5. Record the MLRO’s decisions to report externally or not.
Being practical about all this means that there are eight things relating to AML for every client that need to be in place at all times:
1. Risk assessment (RA) of the client and their business;
2. Evidence of identity that the client actually exists (photo and address ID);
3. List of the names of the management of the entity;
4. Based on RA – get evidence of identity for management;
5. List of beneficial owners (BO)> 25% of capital/profits/votes;
6. Based on RA – get evidence of identity for BO – these must always be individuals;
7. Sufficient Know Your client (KYC) information about the company to help understand what is ‘normal’ for the client and
8. Written evidence should be available that steps 1-7 are always up to date.
When the client is an individual, you need to have evidence that numbers 1, 6, 7 and 8 are in place.
Last of all, carry out a regular documented review (called an Annual Compliance Review) of all the above and retain evidence of this review, even if there is no need to change the risk rating or due diligence carried out on your clients.
To hear more about your AML risks and responsibilities come to our three hour CPD course on 16 December 2015 at the Camden Court, Hotel Dublin 2, from 9.30am to 12.30pm. For booking and more information go to EventBrite
