The danger of an old FWRA

Every accountant knows that you would not rely on old tax books to advise your clients. What is less well known is that AML compliance has moved on considerably, even over the last 4 or 5 years. Documents and systems which used to be acceptable are now regarded as inadequate.

Recently I spent a day with a firm of accountants who were using templates for their Firm-wide Risk Assessment, their AML Policies & Procedures document, and their individual client due diligence and AML risk assessments which they had purchased from a reputable supplier a few years ago. But when their AML compliance was reviewed by their supervisory body they got a fail – and rightly so, in my opinion.

So my tip would be, check with your supplier that you have up to date templates for your FWRA, P&P and CDD documents. Do not assume that what used to be OK will still be acceptable.

Ask yourself – If I knew nothing about my firm and I was given our FWRA and P&P (which HMRC refer to as a Policies, Controls & Procedures document) and read them would I then have a good understanding of the firm, the services it offers and the nature of its clients? If not, then revise these documents!

If you think that you may not have sufficient documentation to satisfy your AML supervisor to a satisfactory standard, or would simply like to discuss your firm’s AML compliance, then please contact us now.

David Winch MLRO support services ltd

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