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AML - the essentials: November 2018

The eleventh issue of 'Anti-money laundering - the essentials' covers OPBAS, whistleblowing and anti-money laundering news such as the launch of the National Economic Crime Centre.

Regulatory updates

OPBAS levy

The Office for Professional Body Anti-Money Laundering Supervision (OPBAS) levies an annual charge on all professional body supervisors (which includes ICAEW), based on the number of beneficial owners, officers and managers in the firms registered with us for AML supervision. ICAEW is passing on this charge to UK practicing certificate holders, to cover additional regulatory work required by these new regulations. You can find out more at icaew.com/regulatoryfees

OPBAS fees consultation

OPBAS has released a consultation on how the fees are calculated which closes on 14 December 2018. ICAEW will submit a response in the next few days.


If you come across an accountancy service provider (ASP) or trust and company service provider (TCSP) that does not appear to be regulated under the Money Laundering Regulations 2017 or appears to be ignoring the regulations, and you want to report it confidentiality, you can do one of the following:

  • Contact their anti-money laundering supervisor
    • If their supervisor is ICAEW, you can report this to us confidentially at icaew.com/complaints.
    • If ICAEW is not their AML supervisor, you should contact the relevant supervisory body.
  • Contact the HMRC MLR Registration Team on their confidential enquiry line +44 (0)1702 366 312 

Information you can disclose

The more detail you can give, the easier it will be for us to consider what our response should be.

The following information is all useful:

  • The names of any individuals involved.
  • Any key dates you know about.
  • The ‘how’, ‘what’ and ‘where’ of any supporting documents or evidence.
  • The type of wrongdoing and who else knows about it.

You don’t need to give us your identity or contact details, although it would make it easier if we need to clarify things or ask for further information. If you have provided contact details then we may well proactively contact you if we require any further information, unless you specifically ask us not to.

Have you obtained your criminal record checks?

Since 26 June 2018, all our supervised firms must take reasonable care to ensure no-one is appointed, or continues to act, as a beneficial owner, officer or manager (BOOM) without ICAEW’s approval. ICAEW can only approve a BOOM if that individual has no relevant unspent criminal convictions and so, to prove that we can approve a BOOM, we require all BOOMs to obtain criminal record check certificates. We will need to see copies of these at your next Practice Assurance visit.

Visit icaew.com/criminalchecks for more information and FAQs.

HMRC’s TCSP register – is your firm on it?

This is a reminder that under Regulation 54 of MLR17, HMRC must maintain a register of all firms that provide trust or company services. If you perform TCSP work when not on the register, you may be subject to disciplinary action. ICAEW has notified HMRC of all the firms it supervises that perform TCSP work.

For details of how ICAEW has identified the relevant firms, visit icaew.com/tcsp 

Anti-money laundering news

Law Commission Consultation on reform to Suspicious Activity Reports

In July 2018 the Law Commission issued a consultation to review the UK’s Suspicious Activity Report regime, and to propose ways to address the problems with the existing reporting regime, including low-quality reports. The consultation also considers how to make the consent regime more effective.

Know the signs, report the crime

The National Crime Agency’s National Strategic Assessment in 2017 found that previous figures of the money laundering impact in the UK of £36 billion to £90 billion could be a significant underestimate.

In light of this, the Home Office are again running the ‘Flag It Up’ campaign with a theme of ‘Dirty Money’, and ICAEW are working closely with the government to support the campaign. This joint initiative is to raise awareness of the warning signs of money laundering, and ultimately to help professionals to protect themselves and their firms.

Launch of the National Economic Crime Centre

Government has launched the National Economic Crime Centre, which brings together colleagues from law enforcement, government and the private sector. Not only will the NECC ensure that criminals defrauding British citizens, attacking UK industry and abusing UK financial services are effectively pursued; it will ensure that UK’s industries and government agencies know how to prevent economic crime and the UK’s citizens are better protected.