The latest CCAB Guidance on Money Laundering has just been issued and it’s a timely reminder that we all need to review our ML procedures in the light of 4MLD and the recent formation of OPBAS to oversee the supervisory bodies.
OPBAS have not been formed to simply tick a few money laundering boxes and it’s fair to assume that their formation will bring more activity or possibly more focused activity by our supervisors.
Nevertheless, the issue of the guidance by the CCAB will help all accountants in practice to focus on their Money Laundering responsibilities especially in light of the issue of the recent 4th Money Laundering Directive where particular attention was focused on risk Assessments.
The section of the guidance on Risk Assessments has the following section headings which deal in some depth with the fact that risk assessments should not be reduce to tick box exercises.
“RISK BASED APPROACH”
- What is the role of the risk based approach?
- What is the role of senior management?
- How should the risk analysis be designed?
- What is the risk profile of the business?
- How should procedures take account of the?
- What are the different types of risk?
- How important is documentation?
There are some changes to previous guidance finally recognising that sole trader accountants are in a very different place than larger practices for example they recognise that sole trader accountants don’t have to actually formally appoint an MLO and this recognition of the realities of being a sole trader accountant are to be welcomed.
The guidance is available to download from our website at http://www.icpa.org.uk/about/ccab_anti_money_laundering_guidance_for_accountancy_sector and it is well worth reading and reviewing your present procedures in the light of the new guidance before your supervisory body most certainly will.
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