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ICAEW regulatory round-up: September 2021

Author: ICAEW Insights

Published: 28 Sep 2021

This month’s regulatory content includes recently published anti-money laundering guidance, new anti-money laundering resources from ICAEW, and a consultation regarding changes to Statement of Insolvency Practice.

Recently published anti-money laundering guidance includes:

  • The Government’s publication on SARs disclosures in civil litigation cases. The publication sets out the Government's position on the use of SARS in private civil litigation matters and provides guidance to help protect reporters of SARs, the subject of SARs and the integrity of the SARs regime. Firms should consider how they can apply the guidance to protect themselves and to maintain the wider effectiveness of the SARs regime.
  • An updated list of high-risk third countries. Money Laundering Regulations require the UK regulated sector to apply enhanced customer due diligence in relation to high-risk countries. The government has published Money Laundering and Terrorist Financing (Amendment)(No.2)(High-Risk Countries) Regulations 2021 which substitutes the list of high-risk third countries specified in Schedule 3ZA with a new list. The new list replicates those countries listed by the Financial Action Task Force (FATF).
  • Reminder about potential crime links in Afghanistan. The Office of Financial Sanctions Implementation has issued an alert to businesses setting out a reminder that within the Taliban, there are a number of sanctioned individuals and that UN sanctions are already in place against individuals and entities associated with the Taliban.

Given this heightened risk context, those engaging or considering engaging in any financial activity in relation to Afghanistan should:

  • consider conducting enhanced due diligence including in respect of entities that may be owned or controlled by designated persons
  • check the consolidated list and consider seeking independent legal advice before undertaking any activity

Members of the Taliban are listed under the UN Afghanistan regime. Individuals and entities with links to the Afghan Taliban are also listed under the ISIL (Da'esh) and Al-Qaida sanctions regime. Read the FCA’s statement on this issue

New anti-money laundering resources

ICAEW’s AML supervision team has launched a series of bite-sized videos covering topical AML issues. The recordings are approximately 10 minutes long and are designed as a refresher for regulatory contacts and for use as a staff training tool. The first four videos are available here

Back to the office: seize the opportunity to refresh your AML culture

The return to office-based working offers the ideal opportunity for MLROs to reflect on changes to the risk landscape over the past 18 months, check their firms’ AML policies and procedures remain fit for purpose, and refresh staff training. 

Does your firm have the right insurance cover for cyber risks?

Changes to ICAEW’s minimum approved wording for Professional Indemnity Insurance have clarified the extent to which policies cover cyber-related claims. What do the changes mean, how are cyber risks evolving and what can you do to ensure your firm has the right protection?

Understanding the charity: the key to independent examinations

This year’s Quality Assurance Department monitoring reviews are focusing on assurance reports, including independent examination reports on charities. We look at the issues the reviewers are interested in, where the pitfalls lie, and how you can avoid them.


The Joint Insolvency Committee consultation regarding changes to Statement of Insolvency Practice 3.1 remains open until 5 November. Give your view

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