AML - the essentials: July 2020
Welcome to AML – the essentials, your regulatory update containing the latest AML information and guidance.
In this issue:
Coronavirus continues to create exceptional circumstances for our members and firms. We have highlighted some resources to help and support you during this period. We continue to expect the highest professional standards, which includes abiding by regulations and continuing to meet the high standards expected by the public.
This report highlights our quality assurance reviewers' most common findings, includes tips on how to avoid these issues and details upcoming changes to our approach.
National Strategic Assessment of Serious Organised Crime
The NCA published its assessment of the factors that enable serious and organised crime in April 2020.
ICAEW risk bulletins
We are sending regular AML Risk Bulletins to money laundering reporting officers (MLROs) and money laundering compliance principals (MLCPs) only at our supervised firms. We sent the first on 19 May 2020, the second on 9 July and the next is due in a few weeks. The bulletins are sent to the email addresses we hold on our records, as confirmed in your most recent annual return. Certain documents are protected behind the member log-in, however MLROs and MLCPs who are not ICAEW members can still access the material by registering on our website. Please contact us via webchat if you have any problems.
These alerts should not be disseminated outside of your firm. The information they contain is for internal use to inform training and any changes to your risk assessment procedures.
Fraud Advisory Panel watch group
The Fraud Advisory Panel has set up a COVID-19 fraud watch group.
Fraudulent COVID-19 claims: what to do if you suspect your client
There are various government schemes to provide financial support for businesses during the pandemic but these are unfortunately open to abuse. ICAEW firms are well placed to not only identify and report fraud, but in some cases to prevent it happening in the first place. We have put together some information on what to do if you suspect your client of fraudulent claims:
Important resources and publications from the National Crime Agency
The NCA has published a number of important resources over the past three months. We strongly recommend that you read the documents and use the information to inform training and any changes to your risk assessment procedures.
The resources include:
- COVID-19: Observations from the UKFIU on what is being seen in reporting around COVID-19 and SARs (May and June editions)
- SARs In Action – May 2020 edition
- Updated SARs glossary codes and reporting routes (May 2020)
- Guidance on submitting better quality SARs (May 2020)
Suspicious Activity Reporting Guidance
Read our new guidance on suspicious activity reporting and how to submit a good quality SAR.
Have you got a SARS Online account?
All firms should have a SARs Online account so that they can report suspicious activity to the NCA.
ICAEW’s AML Supervision Report 2020
We have also published our 2020 AML supervisory report as required by our oversight bodies. Read how ICAEW discharges its obligations as a supervisory authority under MLR17.
AML Guidance for the Accountancy Sector
Following the implementation of the Fifth Money Laundering Directive, work is underway to update the CCAB AML Guidance for the Accountancy Sector to reflect the changes. As this guidance is HM Treasury approved, the updates will also be sent to them for endorsement before full publication.