What’s the worst that can happen?

My heart sinks whenever an accountant concerned about his firm’s failure to comply with the money laundering regulations asks me, “What’s the worst that can happen?” Partly because my focus is not on the worst that can happen, it is on fixing whatever AML compliance problems exist – and usually that is not a terribly difficult job if you know how to go about it.

Maximum penalties

But let me answer the question. At worst a failure to comply with a requirement under the Money Laundering Regulations 2017 in the UK could result in (i) a sentence of up to 2 years imprisonment, and (ii) a fine, and (iii) confiscation related to the benefit obtained from the offending, and (iv) disqualification from acting as a beneficial owner, officer or manager of an accountancy practice for a further period of 4 years after the end of the sentence.

Is that likely? Absolutely not!

The real problem

But what is likely if your firm has significant shortcomings in its compliance with the requirements of the Money Laundering Regulations is a period of considerable anxiety while your compliance is reviewed by your AML supervisory body and possible disciplinary penalties are considered. Frankly it is not the actual penalty which is the problem – frequently the accountant will experience relief once the penalty has been determined and the disciplinary process has concluded.

I have had accountants telling me they cannot sleep and saying things like, “I employ ten people – are they going to lose their jobs?”

The simple solution

So my advice is simple. If you are concerned that your firm’s AML compliance is inadequate, or even non-existent, get in touch now using the link below and we can work together to fix this. The hardest part is getting started!

P.S. Many thanks to Libby Walklett, the Ethical Bookkeeper, for letting me use her photo.

David Winch MLRO support services ltd

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