After the AML Inspection – 5 Most Important Things to Do (and 2 Things NOT to Do)

After the AML Inspection – 5 Most Important Things to Do (and 2 Things NOT to Do)

by | Apr 27, 2024 | News

So you’ve had an AML inspection from your professional body. Now it’s time to pick up the pieces.

Do:

  1. Respond in good time to enquiries from the reviewer (even if it’s merely to acknowledge receipt of correspondence).
  2. Ensure that the information you supply to the reviewer is meticulously accurate and complete.
  3. If asked to select documents relating to clients for submission to the reviewer, select those clients with care, review the documents before submitting them, and provide additional explanations of these documents to the reviewer if that may help.
  4. Keep a copy of everything you submit (or request a copy from your supervisory body if you do not have a copy).
  5. If you are not confident that your AML procedures are fully satisfactory, consider obtaining external assistance before responding to the reviewer.

 DON’T:

  1. Backdate or falsify any documents to be submitted for review.
  2. Waste the reviewer’s time with incomplete or half-baked responses hoping to buy extra time. If you have insufficient time, simply ask for more time at the earliest possible stage of the process.

All our CPD courses are listed here, including our Audit Update webinar.

To hear more about the latest AML developments and how to be on the alert for suspicions of money laundering and terrorist financing under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021, see our latest Anti-Money Laundering webinar here.

Please also go to our website to see our:

  • Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • 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 of attendance in your inbox.
  • letters of engagement and similar templates. Please visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
  • ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please contact John McCarthy FCA by e-mail at john@jmcc.ie.
  • We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. The ISQM TOOLKIT 2022 is available to purchase here.
6 Essentials to Prepare for an AML Compliance Review

6 Essentials to Prepare for an AML Compliance Review

by | Apr 17, 2024 | News

If you have an upcoming AML Compliance Review from your professional body, be sure to follow these six essential steps to prepare.

  1. Ensure that you have an appropriate Policies & Procedures document and a Firm-Wide Risk Assessment accompanied by a note of annual reviews of and amendments to the assessment.
  2. Ensure that relevant staff have received money laundering training accompanied by a record of training completion.
  3. Carry out some test checks of records of your client Risk Assessments and Client Due Diligence documentation to assess whether the firm’s Policies & Procedures are being properly implemented.
  4. Check whether an external AML Compliance Review beforehand might be beneficial.
  5. Check that the information held by your supervisory body about the firm and its MLRO are up to date and correct according to the firm’s most recent Annual Return.
  6. Ensure that all the work which the firm is doing is correctly licensed under the terms of the firm’s authorisation from your supervisory body (e.g. insolvency work and Clients’ Money).

Following these six steps will ensure that your firm is well prepared for its AML Compliance Review.

All our CPD courses are listed here, including our Audit Update webinar.

To hear more about the latest AML developments and how to be on the alert for suspicions of money laundering and terrorist financing under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021, see our latest Anti-Money Laundering webinar here.

Please also go to our website to see our:

  • Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • 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 of attendance in your inbox.
  • letters of engagement and similar templates. Please visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
  • ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please contact John McCarthy FCA by e-mail at john@jmcc.ie.
  • We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. The ISQM TOOLKIT 2022 is available to purchase here.
AML training must be more than mere lip service

AML training must be more than mere lip service

by | Jul 27, 2018 | News

In a recent sanction by the Central Bank, attention is being drawn to the fact that anti-money laundering (AML) training needs to be focused, specific and ongoing. In the sanction report, a financial services firm was fined €443,000 in June 2018 for failures that included lack of appropriate AML training.

The sanctions report reads: ‘it had inadequate policies and procedures to monitor transactions, detect and report money laundering and provide its staff with appropriate training’.

In addition, the Central Bank found that the company:

  • failed in many areas to provide the appropriate amount, level, and accuracy of training for its staff;
  • training was not focused on the specific roles and responsibilities of staff (especially at Money Laundering Reporting Officer (MLRO) level;
  • training did not amount to a sufficient amount of time to train them on how to identify suspicious activity;
  • the entity failed to provide training to all client facing staff; and
  • there was a failure to ensure staff were instructed on AML and counter financing of terrorism (CFT)-related law, and a failure to provide ongoing training.

From 15 July 2010 to 10 September 2012, the firm breached section 54(6) of the Criminal Justice (Money Laundering and Terrorist Financing) Act, 2010, because it failed to train anyone involved in the conduct of its business in AML/CFT law or provide on-going instruction on identifying suspicious activity.

Over a three-year period, the firm had held one-hour annual AML/CFT training session for staff. The Central Bank stated the ‘training was sufficient to introduce staff to AML/CFT law but in further breach of section 54(6), it was insufficient to train them to identify suspicious activity. In addition, the scope of the training was not tailored to specific roles, including the Firm’s MLRO’.

To hear more about the AML requirements that must be applied by accounting firms, including a suggested spreadsheet to control all the main topics, come to our next AML seminar on Tuesday 25 September 2018 at the Talbot Hotel Stillorgan, County Dublin.

Booking is here via our website. Cost is €105 per delegate or €280 for three delegates from the same office.