Accountants & Bookkeepers

All financial institutions, businesses, and gatekeepers are regulated by either the Financial Conduct Authority (FCA), the Office for Professional Body Anti-Money Laundering Supervision (OPBAS), or Her Majesty’s Revenue and Customs (HMRC). The Association of Chartered Certified Accountants (ACCA) and the Institute of Chartered Accountants in England and Wales (ICAEW) serve as the anti-money laundering (AML) supervisors. 

As part of their supervisory responsibilities, ACCA/ICAEW conduct a thorough desk-based review to evaluate your firm’s compliance with the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) ACCA/ICAEW expects all supervised firms, to provide reliable, complete, and accurate information. It is crucial for the accountants to exercise caution when disclosing information about its AML controls. Accountancy firms must identify and assess the specific money laundering, terrorist financing, and proliferation financing risks it faces, and clearly outline how these risks are mitigated. 

Money Laundering Reporting Officer (MLRO) of an accountancy firm is obligated to adhere to the guidelines outlined in MLR 2017. This includes completing, reviewing, and signing off on the following documents annually.

• Customer Due Diligence (CDD)/ Know Your Customer (KYC) – Risk mitigation, Risk review, Risk classification of all clients, AML searches, Sanction searches, Adverse news searches, PEP searches, and proliferation financing searches. 
• Account Activity Review, Red Flags/Internal Suspicious Activity Reports (SAR), and Escalation to the National Crime Agency (NCA). 
• Policy Packs:
  • AML policy, controls, and procedures (PCP) 
  • Anti-Bribery & Corruption Policy 
  • Data Protection Policy Computer Use Policy 
  • Website & Social Media Policy
• AML Training of staff, training material, certificates, and training log. 
• Firm-wide risk assessment (FWRA).