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.
