AML - the essentials: November 2019
Issue 15 of our Anti-Money Laundering update includes an update on the Fifth Money Laundering directive and two new pieces of supplementary anti-money laundering guidance from CCAB.
In this issue
5MLD must be transposed into UK law by 10 January 2020. The Government is working on the revised money laundering regulations and CCAB is revising its guidance.
We are aware that certain electronic ID providers are writing to firms suggesting that electronic ID verification will become mandatory under 5MLD.
5MLD will include a provision that electronic ID verification may be used as an independent and reliable source of ID if the process is:
- secure from fraud and misuse; and
- is capable of providing an appropriate level of assurance that a person is who they say they are.
It is not a mandatory requirement.
- supplementary guidance for tax practitioners (approved by HM Treasury under ML17)
Note, this is not standalone guidance; it must be read in conjunction with the CCAB’s Anti Money Laundering Guidance for the Accountancy Sector.
- Draft supplementary guidance for insolvency practitioners (not yet approved – HM Treasury is not able to approve this guidance until after the general election.)
The NCA has recently published:
- 2019 SARs Annual Report – The 2019 report shows a slight decrease in the number of SARs submitted by accountants compared with the prior year.
- SARs In Action (November 2019) – Articles include: Challenger banks and SARs, Partner agencies and SARs exploitation, Case studies and regime news
- New Glossary codes and reporting routes – The revised booklet replaces all previous publications and includes new codes.
The annual charge from the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) is set to increase for 2020. The £49 levy will be charged to all mainland UK ICAEW practising certificate holders. This will fund the operational costs of OPBAS and it will be used to address the findings of the OPBAS supervisory assessment.