AML Risks Increasing

AML Risks Increasing

The risks of money laundering occurring are changing all the time. At a recent ACCA Ireland Conference one of the talks was on AML and it was highlighted that while over 47,000 Suspicious Transaction Reports (STRs) were filed in Ireland in 2022, only nine were filed by accountants and only one by an auditor. Only 492 accountants and 51 auditors are registered on GoAML which is the online reporting portal for reporting suspicions of money laundering and terrorist financing. More accountants and auditors are strongly encouraged to sign up.

Some of the more recent economic crime trends that accountants need to watch out for include:

Trafficking in human beings

  • Significant cash lodgements from different parts of the country;
  • Significant mobile phone top-ups and property rental payments;
  • Lower-than-expected employee labour costs;

Investment fraud

  • Little or no separation of client and business funds;
  • Investment returns that are too-good-to-be-true;
  • Small payments back to clients (5%-10%) within a few weeks of the investment
  • Trade-based money laundering -including (but not limited to) charging ridiculously high prices to customers;
  • Funds being ‘pooled’ in business accounts and transferred to accounts abroad to purchase goods that are then shipped to their final destination;

Emerging challenges

  • Cryptocurrency and blockchain: it is important to understand what product in this area your client is providing;
  • Virtual IBANs: If you see someone providing these, there is a risk of abuse for fraud and money laundering.

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 (March 2022) available here, which accompanies the AML Manual. It explains the current 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

We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. The ISQM TOOLKIT 2022 is available to purchase here.