David Winch had the pleasure of speaking at Accountex Manchester on 19 September 2023 on the topic of AML Compliance. This article mentions the key points from that session.
Each accountancy firm is unique
It seems that every firm of accountants claims on its website that it is different! But the truth is that every firm is unique. The experience of its staff is unique. The make up of its clients is unique.
But it should follow that every firm’s Firm-wide AML Risk Assessment and Policies & Procedures document should be unique. It is not sufficient to download the template offered by your supervisory body and simply type your firm’s name across the top.
The supervisor’s Big 3
The three items which your supervisory body is likely to focus upon if your firm is selected for an AML Compliance review are your
- Firm-wide AML risk assessment
- AML Policies & Procedures document
- AML Training records
HMRC refer to the Policies, Controls & Procedures document rather than the Policies & Procedures document – but it is the same thing.
Beyond that the supervisor will most likely ask for a few examples of individual client due diligence and risk assessment records to ensure that your firm is operating in accordance with the procedures set out in its policies & procedures document, and perhaps an example of a Suspicious Activity Report form submitted by you to the NCA.
Each supervisory body is different
Each of the supervisory bodies has its own approach to supervision – and to their member’s AML compliance failings. Some are much more likely to consider penalties where there has been a compliance failure.
Disciplinary proceedings are particularly likely where the firm has previously misled the supervisory body regarding the existence of a firm-wide AML risk assessment and policies & procedures document.
In any event where the member is able to say that AML Compliance failings have been promptly addressed upon discovery that will mitigate any penalties which would otherwise have been imposed.
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.
