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Money Laundering: International Law and Guidance

International anti-money laundering requirements, set on a global or regional basis. Representations and training.

The Financial Action Task Force

The Financial Action Task Force (FATF) is an inter-governmental body whose purpose is the development and promotion of national and international policies to combat money laundering and terrorist financing. Its 40 Recommendations are backed by mutual evaluations of its member countries. Countries which are not members of FATF may be members of a FATF-style regional body.

For convenience, the ICAEW has extracted those Recommendations that apply to professional accountancy firms into a single document

In consultation with members of the accounting profession, FATF has also issued Risk Based Approach Guidance for Accountants and a report on Virtual Currencies and AML Risks.

European requirements

The European Federation of Accountants (FEE) has a Money Laundering Task Force, which coordinates AML policy for the profession across Europe, including lobbying the European Commission and FATF. 

The European Union's current requirements are as laid out in the money laundering directives.

The final text of the Fourth EU Money Laundering Directive has been published (adopted by European Council in April 2015). This is expected to become EU law by May after which member states will have 2 years to implement into domestic law.

The Federation of European Accountants (FEE) has published two information papers on the new directive.

US requirements

The United States of America has strict federal AML systems and procedures requirements on banks and certain other financial institutions, which tend to have extra-territorial effect, through requirements for US banks to control their relationships with correspondent and shell banks. As at September 2014 the AML procedures requirements of the US Patriot Act do not apply to non-financial institutions including accounting firms and law firms. Nor are these institutions required to file SAR's.

International presentations and articles

Felicity Banks, ICAEW's Head of Business Law, has contributed articles and presentations to audiences internationally.