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.
