by John McCarthy Consulting Ltd. | Jan 31, 2025 | Blog, News
In last week’s blog we discussed the CPI, or the Corruption Perceptions Index (CPI) often used by MLROs as a supplementary tool to assist in their understanding of money laundering risks in overseas territories.
There are other tools available to MLROs and senior staff in accountancy firms which can also be of great assistance in assessing whether natural persons or other legal entities are in any way connected to high-risk third countries (HRTC). Applying enhanced due diligence is normally recommended in dealing with such countries.
HRTC is defined as: ‘a country named on either of the following lists published by the Financial Action Task Force as they have effect from time to time—
We strongly recommend that accountants access this website on a regular basis (the list changes three times a year) as the current HRTC will change again after the FATF Plenary meeting in February and will change in June and October 2025.
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
by John McCarthy Consulting Ltd. | Jan 31, 2025 | Blog, News
The CPI, or the Corruption Perceptions Index (CPI) is (according to the publishers Transparency International) the leading global indicator of public sector corruption and provides a comparative snapshot of 180 countries and territories. It is often used by MLROs as a supplementary tool to assist in their understanding of money laundering risks in overseas territories.
The next index, which will be for 2024, will be published on 11 February 2025 at this link.
Transparency International (TI) is a Berlin based non-profit organisation set up by former employees of the World Bank. The index is calculated using data from 13 external sources (including interviews of businesspeople around the globe) and scores countries out of 100, meaning that the higher the score, the lower the level of corruption is in the country. In the 2023 index, Denmark came out best with a score of 90.
Ireland has a score of 77 out of 100 in the 2023 index, with no change since 2022, meaning it ranks 11th out of 180 countries.
In its 2023 report it criticises the lack of access to the Irish RBO register about companies’ real owners which was significantly restricted for civil society and journalists across the EU. It states ‘Ireland for example, currently requires journalists and activists to provide not only proof that they are engaged in anti-money laundering work but also demonstrate that a company of interest is connected to financial crime. In practice, this may hinder most access requests as this approach expects applicants to already know the very information they are seeking to uncover. With Ireland’s importance as a financial centre growing, the country needs to ensure utmost transparency in the ownership of all types of vehicles that are currently vulnerable to abuse.’
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
by John McCarthy Consulting Ltd. | Jun 11, 2021 | Blog, News
In a May 2021 report by Transparency International (TI) called ‘Access Denied? Availability and Accessibility of Beneficial Ownership Data in The European Union’ the authors explain how the great majority of countries across the European Union (24 out of 27) have a private central beneficial ownership information register in place. The three that do not are Italy, Hungary and Lithuania.
Access to the registers varies a lot across Member states and while some charge an access fee, others charge a fee, the most expensive being Sweden at €27 per request.
In Denmark, one may check all the companies on the register with the same beneficial owner as well as all companies registered at a given address. It is also possible to search by company (exact name or parts of the name) and by beneficial owner.
It’s a pity that the UK is excluded from the report’s findings which, only deal with EU Member states. Nevertheless it’s a very useful tool to help MLROs track beneficial ownership data of their clients.
The report is free of charge and may be accessed here.
For more about accountants’ AML compliance obligations, see our AML Policies, Controls & Procedures Manual for 2021.
The Manual contains all the latest requirements relevant to accountants contained in the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021 now fully in force. Future blogs will look at various parts of the new and existing provisions of this legislation.
For more blogs please visit this link and for our publications and manuals and services click here.
