| A checklist of additional procedures that need to be applied in accounting practices, company services providers and all other designated persons Legislation over the last 12 months have required the following additional anti-money laundering procedures to be implemented by all designated persons:
- implement a whistleblowing procedure where staff may internally report to the AMLRO any instances of noncompliance with anti-money laundering requirements;
- change engagement letters reference to The Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2010 to 2021;
- check the Register of Beneficial Owners before commencing work on a new client to ensure it is consistent with your understanding;
- file a report of discrepancies if the Register of Beneficial Owners is incorrect;
- if you have a Politically Exposed Person as a client then extend your period of supervision beyond the previously required 12 months;
- amend your standard procedures to require enhanced supervision of clients from high risk countries;
- amend your standard procedures to require enhanced supervision of clients with complex businesses or business structures;
- amend your practice procedures manual to include the new whistleblowing procedure, RBO verification work and other matters above.
ACCA is hosting an intensive anti-money laundering week of courses commencing with a free session on AML monitoring - what to expect and how to prepare on 6 July and followed by a further 3 sessions over subsequent days:
The free online resource material from ACCA to assist a practice become AML compliant is at this link. |
