by John McCarthy Consulting Ltd. | Aug 26, 2024 | Blog, News
Last week we looked at the responsibilities of the MLRO (the Money Laundering Reporting Officer) and some of the items that should be on their ‘radar’.
The MLRO should at least annually document how the AML internal quality control process operates. Ideally this might be in the form of a Memo or in a written report from an external provider. The idea is that the report/Memo triggers actionable items that can be followed up and helps provide evidence that the firm is taking a proactive approach to AML.
Last week we looked at the first five items that should get priority attention. This week we look at the remaining six areas of responsibility that need attention from the firm’s management and the MLRO.
The report should also include the following aspects:
- Ensure that evidence is retained of the sample check of Client Due Diligence (CDD) files that were examined as part of the AML Compliance Review to ensure all information is relevant and up-to-date (e.g. identification is still valid, records match that of CRO and RBO websites, all ultimate beneficial owners (UBOs) and directors have been satisfactorily identified etc.)
- Carry out a Sample check of the documentation of clients’ AML risk assessments to ensure that existing risk ratings are still appropriate, relevant and up-to-date
- Check that the AML Policies, Controls & Procedures Manual is up-to date
- Check that the Firm-Wide Risk Assessment is current and up-to-date
- Check that employees understand the role of ML and their individual responsibilities
- Ensure that recommendations from past internal/external inspections are fully implemented
See more in last week’s blog.
In the meantime, please go to our website to see our:
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- 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 for attendance in your inbox.
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items 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 email 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.
by John McCarthy Consulting Ltd. | Aug 8, 2024 | Blog, News
Every accounting firm is obliged to carry out money laundering checks on clients and support these checks with appropriate documentation.
In this two-part blog we are going to look at the main focus of the Money Laundering Reporting Officer (MLRO). Practically speaking, for smaller firms the MLRO is the sole practitioner – the buck stops with you.
The MLRO should at least annually document how the AML internal quality control process operates. Ideally, this might be in the form of a memo or in a report from an external provider.
The report should include the following aspects:
- Executive summary for the year highlighting any serious compliance deficiencies, together with details of the remedial action that has been taken.
- Review the number and quality of internal Suspicious Transaction Reports (STRs) and consider more focused training where none have been received.
- Number of external STRs submitted to the Garda on GoAML and the Revenue on ROS.
- Number of new clients declined because of unsatisfactory information.
- Details of staff training during the year including –
- Number of AML courses
- Details of new/existing staff attending;
- Issues/queries/misunderstandings clarified
- Supporting evidence of AML training and proof of understanding with documented quiz assessment results and supporting attendance certificates.
See more in next week’s blog.
In the meantime, please go to our website to see our:
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- 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 for attendance in your inbox.
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items 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 email 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.
by John McCarthy Consulting Ltd. | 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.
