Regulatory update
Discrepancy reporting: 1 April
From 1 April 2023, an amendment to the Money Laundering Regulations came into effect that requires firms to report a material discrepancy on a person of significant control (PSC) or registrable beneficial owner of an overseas entity throughout the business relationship. Previously, you only needed to check for discrepancies on a PSC at the beginning of a client relationship.
Companies House has issued guidance on how an obliged entity can make a report if there's a material discrepancy between the information it holds about a PSC or registrable beneficial owner of an overseas entity, and the information on the Companies House register. This guidance will also be replicated within the AML Guidance for the Accountancy Sector (AMLGAS).
Economic Crime Levy
The Economic Crime Levy (ECL) is an annual charge on firms who are supervised under the Money Laundering Regulations and whose UK revenue exceeds £10.2 million per year. Affected entities will have to register for the ECL, submit a return every year and pay a fee every year. The first payments will be due by 30 September 2023.
Checking the evidence: is your client who they say they are?
ICAEW's anti-money laundering (AML) team and AML experts offer tips on how to source reliable evidence to verify that your client is who they say they are.
SARs reporting
New SARs Portal
The UKFIU will release the new SARs Portal for firms to submit their Suspicious Activity Reports over the coming months. This will be a phased release, and firms will be invited to create an account in the new system. Once a firm has created the new account, all SARs should be submitted in the new SARs Portal.
Resources to support firms using the new portal:
Make sure SARs stand up to scrutiny
The past year has seen a ramping up of submissions of Suspicious Activity Reports. Michael Jones from the UK Financial Intelligence Unit explains how accountants can best play a vital role in combating crime.
UKFIU resources
The UKFIU has published new resources to support firms in improving the quality of the information they submit via suspicious activity reports:
Reminders
Disciplinary update
Take note of the latest disciplinary cases to ensure you or your firm are not making similar mistakes.
Register of Overseas Entities – AML risks
Read about the money laundering risks of Register of Overseas Entities verification work.
Confirming AML supervision to HMRC
How to avoid losing access to your agent account.
ICAEW cyber round-up: March 2023 and April 2023
Read an overview of all the recent cyber activity.
Guidance on the prohibition of audit services to Russia
Ban on audit and trust services to Russia in force.
Updates to ICAEW's disciplinary framework
On 1 June 2023, revisions to ICAEW's disciplinary framework will come into effect. Access the new bye-laws and regulations and find out more.
Review of ICAEW's Professional Indemnity Insurance Regulations
ICAEW is conducting a review of its professional indemnity insurance (PII) requirements. The aim is to ensure that the arrangements remain fit for purpose and provide adequate protection to the public while being mindful of the cost to the profession.
Resources
Updated compliance review checklist now available
This checklist has been put together by the Quality Assurance Department. It is designed to help firms to carry out an anti-money laundering compliance review, ensuring a quality output with effective risk management.
Firm-wide risk assessments
Join ICAEW's anti-money laundering supervision team to gain an understanding of how to conduct an effective firm-wide risk assessment.
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- AMLbites: Risks and red flags - Open source checks
AML risk webinar recording
Watch our latest AML webinar, focusing on risk.
Money laundering risks: Q&A
The Q&A session in ICAEW’s recent webinar on money laundering risks highlighted a range of issues. We pick out some common themes, and experts from ICAEW's anti-money laundering (AML) team and leading firms provide responses to key questions.
Professional money launderers (PML) and their impact
Find out the impact PML have on the accountancy sector.