Apply for AML supervision by ICAEW
We have an important role as the largest accountancy professional body supervisor in the UK, supervising around 11,000 firms. Our strategy is to provide robust anti-money laundering supervision through a risk-based regime, focussing our efforts on those firms where the risk that they will be used to enable money laundering is highest.
Find out how your firm can apply for AML supervision by ICAEW
AML supervision – ICAEW members firms
We automatically supervise our member firms under MLR17 through ICAEW’s PA scheme.
It is important that ICAEW members check that their firm meets the definition of an ICAEW member firm and are therefore in the PA scheme and supervised by ICAEW for AML.
AML supervision – non ICAEW member firms
There are many situations where firms are within the scope of MLR17, and require AML supervision, but are not automatically supervised and subject to ICAEW’s PA scheme because:
- The scope of the regulations is wider than ICAEW’s requirement for a practising certificate (PC). Firms may be providing services within the scope of the regulations (eg, company formation) for which a PC is not needed.
- Members, or firms, may be providing accounting or other services in a way that does not require a PC; eg, as interim managers but that may fall within the scope of MLR17.
- Members may hold a PC but they are working in non-member firms. So although they may be individually subject to PA, the firm is not.
- The firm doesn’t meet all of the elements of the member firm definition eg. the firm’s structure may meet the member firm definition but the firm isn’t in public practice because the accountancy services account for less than 10% of the total income of the firm.
Firms that don’t meet the definition of a member firm but are within the scope of MLR17, can apply to ICAEW to join the PA scheme and register for anti-money laundering supervision. In order to apply, at least one principal in the firm must be an ICAEW member or an affiliate member, or the firm must be owned by a firm which has at least one ICAEW member or affiliate member as a principal.
We can also supervise members of Global Accounting Alliance (GAA) bodies for the purpose of anti-money laundering (AML) compliance through its Practice Assurance programme.
Anti-money laundering (AML) supervision for insolvency firms
ICAEW is the AML supervisor of its member firms. This supervision covers all accountancy services and firm-wide areas, including insolvency.
ICAEW supervises AML procedures on regulated and related work carried out by insolvency practitioners (IP) who have a licence with ICAEW. If the IP is working in a non-member firm, we need to know who the firm-wide AML supervisor is. If the firm doesn’t have an AML supervisor, non-member firms can apply to ICAEW for firm-wide AML supervision if one of the principals (partner, member of an LLP or director of a corporate entity) is an ICAEW member or affiliate.
Unsure about who your supervisory authority is?
This ICAEW flowchart is used by the Accountancy Affinity Group to help firms / ICAEW PC holders identify who their supervisory body should be. Please note it does not explain how the supervisory authority will supervise. For example, the flow chart indicates that ICAEW is the AML supervisor of a non-member firm, that is audit-registered or DPB-licensed with us. However, the firm must apply for an agreement for Practice Assurance services as it is not an ICAEW member firm and not included in the Practice Assurance scheme.
If you have any questions about how to apply the flowchart to your circumstances, you can call Advisory Services on +44 (0)1908 248 250.
FCA authorised firms
The Financial Conduct Authority (FCA) has stated it will supervise our firms that are also authorised firms under the Financial Services and Markets Act for FCA-authorised activities. We will supervise non-authorised activities through our PA scheme for our member firms. If your firm is not a member firm, it will need to apply for separate supervision of the non-regulated work. We continue to liaise with the FCA and other supervisors to prevent overlapping AML/CFT regulation.