As the New Year starts, anti-money laundering compliance will be anything but the number one priority for most practitioners – especially with everything else that’s going on!
Nonetheless it’s an area that Professional Bodies are always extremely focussed on, so here are five key questions to ask yourself as 2021 begins, especially if you are your firm’s money laundering reporting officer (MLRO):
1. Is our firm level risk assessment up to date?
The ‘firm level risk assessment’ was, of course, something that was introduced in 2017. For many small firms it does not feel like a particularly helpful process.
It is something that professional bodies do look at though – and we increasingly hear that practices are getting quizzed on whether their assessment has been updated at all since 2017, a very valid question given how much firms, their clients and the economic environment have changed during the tumultuous year that was 2020. Could now perhaps be the time to dust down and update your firm level risk assessment?
2. Are we due some ‘internal audit checks’?
The AML regulations require all practices to have an ‘internal audit function’ dealing with AML compliance, which means that you periodically need to carry out spot checks yourself to ensure that all paperwork is up to date. Pick a sample of clients and check that there is a risk assessment, initial due diligence checks and then ongoing risk assessments and updates.
Such a review may be difficult to do if you and your staff are working remotely but remote reviews are exactly what professional bodies like ICAEW and ACCA are performing at the current time so it could be great practice for the ‘real thing’ especially if you know that you have a compliance visit coming up!
3. Is everyone trained?
As a result of changes introduced by the 5th AML Directive, MLROs need to be sure that all subcontractors and secondees, as well as employees, are trained so now could be a good time for a thorough review of training records to ensure that this is the case.
For anyone who has not been trained or whose training record is out of date, Insight Training’s brand new AML e-learning programme could be just what you need. Click here for more details.
4. Is training sufficiently tailored?
Tailored training means training staff on ‘red flags’ relevant to your business and thinking about the specific issues that they need to consider based on the day-to-day work that they do.
The money laundering risks someone working in corporate finance will need to think about contrast sharply with the issues relevant to those working in accounts & audit or insolvency or personal tax. Internal team meetings are a great vehicle for discussing sector specific issues. Don’t forget to document these discussions within staff AML training records.
A useful ICAEW paper here provides interesting insights into the sort of issues that firms report to the National Crime Agency by submitting Suspicious Activity Reports (SARs).
5. Has everyone been appropriately ‘screened’?
To us screening means two completely different things.
Firstly, remember that criminal record checks need to be carried out for newly promoted principals, and original documents kept to show to your professional body at the time of an inspection visit.
Secondly, screening means testing people to check retention of topics covered during training interventions. Again, Insight Training’s new AML e-learning programme has everything that you need here. Having completed the training modules, participants will complete a multiple-choice assessment. If they secure the mark that they need to pass, their score will be emailed across to add to their training record.
In addition to our comprehensive eLearning programme, Insight Training has two AML related training courses planned for Spring 2021. Peter Herbert & Edward Rands will deliver our annual Anti Money Laundering Update on 4 May 2021 (9.30-12.30) and on 14 June (12.30-1.30) Peter and Tim Holt will discuss AML and Fraud Hot Topics as part of our Spring 2021 ‘CPD Bites’ programme. For more information and to book on, click here.
