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AML - the essentials: August 2019

Issue 14 of our Anti-Money Laundering update includes a new electronic due diligence helpsheet and reports and resources from the Government, HM Treasury and the Law Commission.

Regulatory updates

The Government’s Economic Crime Plan, 2019-22

The plan provides information on action being taken by the public and private sectors to ensure that the UK cannot be abused for economic crime.

HM Treasury has published its Supervision Report 2017-18

This report includes self-reported data about activity undertaken in 2017-18 across the UK’s anti-money laundering / counter terrorist financing regime, which AML / CTF supervisors provided to the Treasury in their annual returns. This report fulfils the Treasury’s obligation under the money laundering regulations, to publish a consolidated review of this information.

Read the latest National Crime Agency reports 

The NCA has published three reports over the summer:

Public/Private Threat Update 2019: This report sets out the key economic crime threats facing the UK that informed the UK’s Economic Crime Plan. The update looks at the latest combined public / private understanding of money laundering, fraud against individuals and businesses, and international bribery.

SARs Reporters Booklet July 2019: A summary of feedback from law enforcement agencies (LEAs) on their use of suspicious activity reports and includes pertinent information and updates from the UK Financial Intelligence Unit (UKFIU)

SARs In Action Magazine August 2019: The UKFIU lifts the lid on the ‘life of a SAR’, examining the whole process of what happens when a reporter has a suspicion of money laundering and includes case studies illustrating the value of SARs information.

Law Commission reports on the SARs regime

The Law Commission’s review on the SARs regime identifies concerns with the quality of SARs and evidence of over-cautious reporting. The report makes 19 recommendations.

Guidance for a Risk-Based Approach for the Accounting Profession

ICAEW co-chaired this update to the financial action task force (FATF) guidance on a risk-based approach. The guidance aims to support accounting professionals in the design of effective measures to manage their money laundering and terrorist financing risks when establishing or maintaining business relationships.

ICAEW responds to Corporate Transparency consultation

ICAEW has submitted a response to the Department for Business, Energy & Industrial Strategy (BEIS) consultation on reforms to Companies House. The proposed reforms include the introduction of identity checks for company directors and those forming companies, to seek to deter the misuse of UK limited companies by criminals.

  • Read the response

OPBAS levy increase for UK practising certificate holders

The Office for Professional Body Anti-Money Laundering Supervision (OPBAS) levies an annual charge on all professional body supervisors (PBSs), which includes ICAEW, to fund its operational costs.

For 2019, we estimated the levy from information given to us by OPBAS on how they would calculate and allocate their fees across the professional body supervisors.
OPBAS has published the outcome of their fees consultation and confirmed the levy for 2020. The levy for 2020 consists of:

  • a flat-fee of £5,000; plus
  • a variable fee of £44.36 for every BOOM in excess of 6,000.

A £49 levy will be charged to all mainland UK ICAEW practising certificate holders for 2020. This fee also includes a charge to cover ICAEW operational changes required to address the findings of the OPBAS supervisory assessment.

Reminder: Sanctions for AML breaches have been revised

The Guidance on Sanctions has been updated to include revised sanctions for AML breaches which aim to deter money laundering by ICAEW supervised firms. These changes came into effect on 1 July 2019.

Anti-money laundering resources

New helpsheet – Electronic due diligence

ICAEW’s Technical Advisory Service has published a new helpsheet to help ICAEW members carry out electronic due diligence.

When to make a SAR flowchart

Law Commission report summarises the decisions a reporter must make to comply with their obligations to make a SAR for both standard and DAML SARs.

Practice Assurance 2019

Maintain high standards: examine the most common failings uncovered during practice assurance reviews. This year's monitoring report and webinar include a focus on AML.

Useful links