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Responsibilities and obligations of an ICAEW member firm

Helpsheets and support

Published: 02 Feb 2021 Update History

This section provides guidance on how ICAEW member firms can meet the obligations and responsibilities set out in the money laundering regulations.

Regulatory framework

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR17) came into force on 26 June 2017. HM Treasury revised MLR17 to take account of the changes required by the fifth money laundering directive (5MLD). The new legislation was effective from 10 January 2020.

The government has also published a statutory instrument to implement changes to the Trust Registration Service (TRS) as required by 5MLD.

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:

Reporting discrepancies in the People with Significant Control Register 

What is required of an ICAEW anti-money laundering (AML) supervised firm?

AML Policies and Procedures template

This template is targeted at new firms, sole practitioners and smaller firms who are looking for guidance on how to structure their AML policy and procedure documentation.

Anti-money laundering for smaller practices

Technical helpsheet issued to help new ICAEW practitioners to comply with Anti-Money Laundering (AML) legislation and guidance.

How can ICAEW firms check they comply?

ICAEW has published a compliance review checklist for firms to use to regular assess their compliance with MLR17 and associated legislation.

The AML Monitoring Report 2020

Prepared by ICAEW’s quality assurance reviewers, this report covers the key issues identified from anti-money laundering reviews carried out in the last 12 months. It aims to help firms understand how to avoid these issues.

AML service

ICAEW has teamed up with SWAT UK to create a package of online systems and insightful online training seminars tailored to meet your requirements.

Criminal record checks

Under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR17) ICAEW must approve all beneficial owners, officers and managers (BOOMs) in our supervised firms.

HMRC TCSP register

Under Regulation 54 of MLR17, HMRC must maintain a register of all relevant persons who are trust or company service providers (TCSPs) that are not already registered with FCA.

UK sanctions and their role within the AML framework

The UK Sanctions Regime has been developed over the same timeframe as the AML regime and has many similar objectives and characteristics but there are also significant differences.

Criminal Finances Act – corporate offence to prevent facilitation of tax evasion

The Criminal Finances Act 2017 targets corruption, money laundering and tax evasion by aiming to recoup criminal assets and is part of the government’s strategic approach to reducing financial crime.

The Act also introduces two new criminal offenses in respect of the facilitation of tax evasion. The new offenses will be committed where a corporate entity or partnership fails to prevent an associated person from criminally facilitating the evasion of tax, whether the tax evaded is owed in the UK or in a foreign country where there is a connection to the UK.

Useful links

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