Low Levels of Suspicious Transaction Reports


According to statistics quoted by Chartered Accountants Ireland recently, there are over 2,100 entities registered to make reports on the GoAML website of the Garda Síochana. This is one of the two websites where anti-money laundering (AML) reports must be made in Ireland. The other being the Revenue Commissioners www.ros.ie website. However the surprising aspect of this is that there are only 194 accountants/auditors on this list.

Each of these firms should be registered on the GoAML site in order to make reports of suspicious transactions involving money laundering. In 2020 there were over 29,000 reports of money laundering suspicions from many industry sectors, to the Garda/Revenue Commissioners.

According to the latest Profile of the Profession report from the Irish Audit & Accounting Supervisory Authority, there were 1,155 statutory audit firms approved to carry out audits in Ireland that had offices in Ireland. Even if a firm has no report to make at the moment, it’s still a good idea to register to be able to access knowledge and information provided by the Garda Financial Intelligence Unit.

This does not even represent the total population of potential registrants, as there are many practicing firms of accountants in Ireland that no longer need audit registration, but will have AML responsibilities, as the law affects all accountants who are principals in firms in practice. The numbers of these non-audit firms are harder to assess, because they would also include bookkeepers as well as those entities specialising in payroll and similar accountancy-related back-office activities. Let’s make an educated guess that there are around 2,000 firms of accountants/bookkeepers in total in Ireland, including audit firms.

The percentage registered is therefore under 10% of the total of potential firms of accountants/auditors that ought to be registered, so it’s no wonder the volume of money laundering reports from accountants annually in Ireland, is so low.

Elsewhere it was reported by the AccountingWebUK in April 2019 that ‘26% of accountants surveyed in the UK, did not have an assigned MLRO in their firm.’ It is one of the requirements of Irish/UK AML law to appoint a ‘nominated officer’ (commonly called the MLRO or Money Laundering Reporting Officer), with ultimate responsibility for the implementation of anti-money laundering policies and training.

For more about accountants’ AML compliance obligations, see our AML Policies, Controls & Procedures Manual for 2021.

The Manual contains all the latest requirements relevant to accountants contained in the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021 now fully in force.  Future blogs will look at various parts of the new and existing provisions of this legislation.

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