Repeating Money Laundering Checks
Question from a firm – When a client moves address, do you need to redo the Money Laundering (ML) verification checks?
Answer – You should obviously update your records and then consider, on a risk sensitive basis, what (if any) evidence you need to support the change (e.g. obtain copy of a utility bill for the new home address – preferably a physical utility like gas/electric/broadband, but not a mobile phone bill). For most clients I would have thought that routine correspondence and dealings with the client would provide sufficient evidence to corroborate the change.
Also bear in mind the need to verify that the related appropriate update has been made to the RBO register entries (which are actually the client’s responsibility). This applies where the client is a beneficial owner of either a limited company or an Industrial & Provident Society. Such updates must be made ‘in a timely manner’ according to SI 110/2019.
Are your AML Policies Controls & Procedures up to date?
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.