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Payroll processing: stop and think about AML

Author: ICAEW

Published: 02 Sep 2022

Firms are using ICAEW’s AML educational drama All Too Familiar to support in-house training in a variety of ways. Caroline Wheeler, partner at Bevan Buckland LLP, tells us how the film helped staff in her firm’s payroll department when they took on an unusual number of new clients.

“We used All Too Familiar in two separate ways,” says Caroline. “First we made the film available on the firm’s intranet for all staff to watch; and second we used it specifically for training staff in the payroll department at one of our offices.”

Bevan Buckland is a leading chartered accountancy firm in South and West Wales, employing around 100 people in five offices across the region. It provides accountancy and audit services to a wide range of businesses and organisations.

“We were taking over the payrolls for around 100 charities,” Caroline explains. “So suddenly we had to do anti-money laundering (AML) checks for all those charities, and it was the payroll department that was tasked with doing it.”

“Having watched All Too Familiar, I decided it was ideal for these staff because one of the key issues played out in the film relates to payroll,” she says. “So the film’s release was perfect timing for us.”

All Too Familiar, which was created in partnership with HMRC, is set around a fictional accountancy firm, Nickel Turner LLP. The drama explores the firm’s relationship with a long term client who receives a significant injection of money to support his ailing restaurant chain.

A key element of the storyline is the outsourcing of the chain’s payroll to a boutique accountancy practice owned by a colleague and friend of one of Nickel Turner’s partners. As the action unfolds, questions start to arise about high staff turnover at the restaurants and changes to the payroll.

“Payroll is probably one of those areas where it's easiest for things to go wrong with AML,” says Caroline. “But it's also often a service that’s a bit separate from other work, which can mean payroll staff don’t always fully understand their part in AML compliance. And, in particular, they might not realise how their role in spotting AML issues can be as equally important as that of someone preparing a set of accounts or doing a tax return.”

Stop and think

Caroline screened the film during a team-wide meeting of the payroll department. She explained its significance for them, not only in general terms but also because of their critical role in the onboarding of the new charities.

“The film really spoke for itself,” she says. “But during our interactive session, we talked about what we thought were the key issues, and I answered any questions and queries.”

She believes all the members of the payroll team found the film useful. “It really helped get across how they need to have professional scepticism, and how they might sometimes come up against people who don’t want to share information.”

“Initially, I think the team was a bit unsure why it was being asked to watch this type of film,” she acknowledges. “But once everyone had watched it and we'd discussed it, they realised it was a good reminder of things they might come across but perhaps wouldn't necessarily identify at first glance as an AML issue.”

“Paying the same rate to all staff, regardless of their role, is possibly one of those things that people wouldn't necessarily have seen as a red flag,” she says. “But they now realise that this could indicate something as serious as people trafficking.”

“When you're regularly processing things coming in and going out, which is what a payroll department, by its nature, tends to be doing, it can be difficult to stop and think,” she suggests. “But that’s where the film helped: people had time to stop and think about what they look at every day, and why it's important to consider exactly what they are processing.”


The firm’s partners and senior managers also found the film useful. “As a firm, we build strong relationships with clients,” says Caroline. “I've got current clients where the firm has acted for their great grandparents, so we've got very strong ties.”

“From my point of view, as a partner, the overfamiliarity in the title really resonated,” she adds. “In such cases, it can be quite easy to become distracted from the fact that knowing someone really well doesn’t mean nothing can go wrong. I think we all found it a good reminder that you still have to be suspicious, and you still have to ask the right questions.”

“You have to make sure you do these checks when something changes within a relationship too,” she stresses. “And for most firms that's probably one of the areas where it's easiest to fall down.”

When you’ve got an existing client who suddenly does something different or brings in just one new person, it can be quite easy to forget that you've now got a new relationship, and you've got to do the checks and do them properly.”

The right balance

For Caroline, the film strikes a good balance in terms of content and length. “It isn’t too long,” she says. “But it is long enough – about 16 minutes – to provide worthwhile information.”

“With a five-minute video, for example, people sometimes put it on the screen while they carry on working, and are not really watching,” she notes. “Whereas with this length, they will probably pay attention without having to worry where their time is going, which for busy practices is always a consideration.”

“Overall, we found the film an easy watch,” she concludes. “I’d recommend it to any accountancy firm. It covers so many different aspects without being too technical or dry. So whether you're a sole practitioner or working at one of the Big Four, you’d probably sit there and think: actually there are elements of this that I recognise.”


Read how All Too Familiar is supporting training across a range of accountancy practices.