A new requirement – to protect firms against the risk of money laundering – came into law last year, but many firms may not yet have prepared the relevant document.
The Fourth Money Laundering Directive (2015/849/EC) was transposed into Irish legislation in November 2018 by way of the Criminal Justice (Money Laundering and Terrorist Financing), (Amendment) Act, 2018 (the “2018 Act”).
One of the main changes introduced by the 2018 Act is that it introduces the requirement in Section 30A to carry out and document a Firm-Wide Business Risk Assessment of the business/firm itself.
To assist accounting entities, we have prepared a Word template which retails for €60+VAT, available at this link.
We have also produced a 44 minute webinar on how to prepare the Firm Wide Business Risk Assessment.
If you have already prepared the document, it may need updated for changes to any of the five key areas listed below.
Our Firm-Wide Business Risk Assessment template is pre-populated with some text to help you prepare the document. You simply remove the example text and insert text that is more appropriate concentrating on the five key areas that under Section 30A. These are:
- Clients of the firm – who are they;
- Products and services provided – how might they be abused for money laundering;
- Countries that our clients operate in and which may present certain geographic risks;
- Transactions we are involved in (e.g. certain clients’ money and similar transactions may pose additional risk); and
- Delivery channels e.g. do we always meet our clients face to face? If you do, this would be a risk mitigating factor.
The document is based on the professional guidance produced by the CCAB in its document called the CCAB-I Technical Release 01/2019.
Please find links here to our:
- Webinar on AML Business-Wide Risk Assessment – €45
- Word template containing all the guidance you should need to prepare the Business Risk Assessment – €60+VAT
Our new fully updated AML Policies & Procedures Manual includes a section that fully deals with these requirements and is now available here. The Manual is updated for the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018 which came into force on 26 November 2018. It retails at €150+VAT.
Once viewing is completed, customers will receive a CPD Certificate confirming their learning.