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AML risk and the risk-based approach

Helpsheets and support

Published: 02 Feb 2021 Update History

This section provides guidance on how ICAEW member firms can effectively design and implement a risk-based approach. We also provide information on AML risk.

AML guidance for the accountancy sector

The CCAB has published updated guidance for the introduction of MLR17. This guidance has not been approved by HM Treasury.

The guidance is addressed to all entities providing audit, accountancy, tax, insolvency or related services in the UK (including firms providing trust or company services) by way of business, irrespective of membership of a recognised professional body.

The CCAB also publishes a separate appendix for:

ICAEW firm-wide risk assessment methodology

MLR17 requires firms providing accountancy, trust or company services to take the appropriate steps to identify and assess the risk that they could be used for money laundering, including terrorist financing. They must assess the services they provide and the types of client they have, to understand how criminals could use them to conceal the proceeds of a crime or use their services to create an arrangement that could facilitate money laundering.

National Risk Assessment 2020

The National Risk Assessment (NRA) of Money Laundering and Terrorist Financing is a stock-take of the UK's collective knowledge of money laundering and terrorist financing risks in the UK. Our summary of the NRA forms part of new resources to support your firm.

AASG Risk Outlook

This Risk Outlook sets out the key AML risks within the accountancy sector. It was produced by the Accountancy AML Supervisors Group (AASG). You should review the risks within the Risk Outlook and consider how your firm may face these risks.

AML risk bulletins

We send regular AML Risk Bulletins to money laundering reporting officers (MLROs) and money laundering compliance principals (MLCPs) only at our supervised firms. The bulletins are sent to the email addresses we hold on our records, as confirmed in the firm’s most recent annual return. The Accountancy AML Supervisors’ Group (AASG) risk bulletins 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.

The AASG risk bulletins’ 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.

ICAEW risk bulletins

Latest articles on AML risk 

What to do if you suspect your client of furlough fraud

Government schemes to ease the financial impact of the Coronavirus pandemic have been a lifeline for businesses. But with measures rushed in so quickly, some will inevitably take advantage.

National strategic assessment on Serious Organised Crime (SOC)

Operationally, the National Crime Agency (NCA) leads and coordinates the UK’s response to serious organised crime. It publishes an annual national strategic assessment on the issue, highlighting key findings and trends.

COVID-19 risk briefing

COVID-19 is creating exceptional circumstances and criminals are identifying ways to exploit the vulnerable. In this risk briefing, we have summarised the key fraud trends and cases we have identified and red flag indicators for the ways in which criminals may seek to use the COVID-19 crisis to launder money.

Guidance on crypto-assets

This guidance gives an introduction to crypto-assets for accountants, and how members may encounter clients with these assets. The guidance then outlines the Money Laundering risks that could be associated with clients who hold crypto-assets, and the issues that members will need to consider in their risk assessments.

Anti-money laundering implications of investments in cannabis, CBD and other cannabinoids

Guidance to alert members to their potential position in relation to clients who have invested in Cannabis in jurisdictions where it has been legalised for medicinal and/or recreational use.

Red flag indicators of modern slavery and human trafficking

ICAEW, along with the other accountancy professional body supervisors, worked with the NCA to identify these red flags for the accountancy sector. Firms should read the indicators and watch the Operation Fort Panorama clip on page 9. Remember to use the SAR glossary code XXMSHTXX in any relevant SARs.

COVID-19: Observations from the UKFIU on what is being seen in reporting around COVID-19 and SARs (May and June editions)

NCA publishes important resources describing what trends and typologies they identify. This document sets out key observations on what is being reported around COVID-19.

Useful links

Please make use of the following resources to ensure you are up-to-date with the latest regulatory information and news: