How is your AML Compliance?
In last week’s blog we wrote about the recent publication of the 2019 Annual Report of the Chartered Accountants Regulatory Board (CARB). The section on Money Laundering inspections will be of interest to readers.
Money Laundering Compliance Review – Every firm is required to perform an annual money laundering compliance review and document it, with findings for follow-up action. The review should involve a thorough examination of the firm’s AML procedures, including their application on client files, a review of the firm’s AML Policies & Procedures Manual and a review of AML training within the firm. Firms are also required to have prepared and documented a Firm Wide Business Risk Assessment.
During any subsequent Institute inspection the remedial action, identified in the firm’s review, will be expected to have been completed or substantially progressed.
AML Training – Firms must have procedures to monitor that all personnel involved in client work (not just client facing staff) receive up to date AML training.
Annual Return declarations – Firms must complete their annual returns every year. Often the AML section has errors. The Quality Assurance Committee of the Institute, to which the Professional Standard Department reports, takes incorrect declarations on the Annual Return very seriously and regulatory penalties can result where inaccuracies are identified during an inspection.
Our February 2020 up to date AML Policies & Procedures Manual is available on our site for immediate download in Word format and it contains everything you need to be up to date.
We also have several audit template letters that are up to date for GDPR and Coronavirus (COVID-19) downloadable for immediate tailoring in MS Word.
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