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AML - the essentials: September 2017

The seventh issue of 'Anti-money laundering - the essentials' covers: new anti-money laundering guidance for the accountancy sector and updated sanctions guidance, resulting in new reporting obligations.

Page last updated

25 August 2017

New anti-money laundering (AML) guidance for the accountancy sector

The guidance has been updated for The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, but also for certain measures in The Criminal Finances Act 2017. There is now new guidance for accountants on whole firm risk assessments, suspicious activity reports (SARs), client due diligence, allocation of responsibility for AML, employee screening, and review of policies and procedures.

The guidance has also been substantially re-written to be more practical and user friendly. Changes include risk assessment diagrams, beneficial ownership illustrations, tables to assist with client due diligence and decision making in respect of SARs.

The updated guidance has been sent to HM Treasury for approval later this year. Approval will mean the courts will have to take it into account when determining if an accountant's conduct gives rise to certain offences under AML legislation. Approved guidance is also taken into account in relevant professional disciplinary enquiries.

Updated sanctions guidance: new reporting obligations

HM Treasury’s Office of Financial Sanction Implementation (OFSI) has updated their Guide to Financial Sanctions to help individuals and businesses understand what they should report and when.

Please note that making a SAR to the NCA does not remove the requirement to make a report to OFSI.