Invoices Lacking Commercial Rationale
In recent blogs we looked at some examples of money laundering in practical day to day business life.
Here is another case study based on an example from the latest Consultative Committee of Accountancy Bodies (CCAB) AML Guidance released in early March 2022.
Your client plans to expand its operations into a new overseas area of operation. The client has engaged a consultancy firm to oversee the implementation, although it is not clear what the firm’s role is.
Payments made to the consultancy firm are large in comparison to the services provided and some expenses claimed are for significant sums to ‘meet government officials’ expenses’.
The country is one where corruption and facilitation payments are known to be widespread. You ask the FD about the matter and he thought that such payments were acceptable in the country in question.
What are one’s AML reporting duties in this situation?
- If you suspect that bribes have been paid – Report the matter as a suspicious money laundering transaction.
- If you do not suspect illegal payments – do not report.
The CCAB-I guidance goes on to clarify that money laundering offences include, in certain circumstances, conduct occurring overseas which would constitute an offence if it had occurred in Ireland.
Please note that few potential money laundering reporting scenarios are clear cut and legal and professional advice may be necessary to fully understand your reporting obligations.
Are your AML Policies Controls & Procedures up to date?
There are no excuses as we have just released our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
We have also just released an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms.
To ensure your letters of engagement and similar templates are up to date 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.
For our latest Audit Quality Control Manual (October 2021) (implementing the latest Irish Audit & Accounting Supervisory Authority standards including ISQC1 on audit quality control) click here. View the Table of Contents here.