Anti Money Laundering - Annual Update and Refresher

Objectives

The aim of this session is to ensure that delegates remain up to date with changes to anti-money laundering (AML) regulations and guidance, as well as considering common issues in practice. The course will also consider issues raised by the QAD on their monitoring visits.

Key topics

THE ECONOMIC CRIME AND CORPORATE TRANSPARENCY ACT 2023 (ECCTA)

• Failure to Prevent Fraud
• What can directors do to protect themselves and the company?
• What are adequate procedures?
• Conclusions

COMPANIES HOUSE AGENT FILING SYSTEM LAUNCHED

• Process
• Why is this being introduced?
• Overview
• Summary of changes
• From 4 March 2024
• From 1 May 2024
• From October 2024
• From 27 January 2025
• From 25 February 2025
• From 25 March 2025
• By Summer 2025
• By Autumn 2025
• By Spring 2026
• By the end of 2026
• Following accounts reform

HIGH RISK THIRD COUNTRIES

• Proliferation financing
• What a material discrepancy is
• Discrepancies that are not ‘material’
• Examples of material discrepancies

MLTFPF RISKS – RED FLAGS

• National Risk Assessment (NRA)
• Regulatory body risk assessment

ICAEW AML MONITORING REPORT 2023/24

• Focus for 2024/25
• Suspicious Activity Reports
• Risk-based approach to supervision
• Compliance within firms
• Improving compliance
• Key findings in non-compliance firms
• Client Identifying
• Assessing Risks
• Verification
• Top 10 issues from ICAEW monitoring visits

A REMINDER OF YOUR REPORTING RESPONSIBLITIES

• The duty to report – its personal!
• Proceeds of crime
• What are your reporting procedures?
• What should a report contain?
• When does speculation become suspicion?
• CCAB guidance about suspicion
• Whether to report
• What if the police already know about a reportable matter?
• Report to the MLRO!
• Legal privilege
• Legal privilege
• Litigation privilege
• Report to the MLRO and let them decide
• Obtaining a DAML or consent
• Tipping off
• Exceptions to the offence of tipping off
• Reporting case studies

UNDERSTANDING CDD

• CDD overview
• When is CDD required?
• Understanding your client
• Beneficial owners
• Getting to know your clients better using open-source information
• Client risk assessment
• Customer risk factors
• Product, service, transaction or delivery channel risks
• Geographical risk factors
• Verification
• What is acceptable evidence?
• Electronic ID checks
• Beneficial owners
• Enhanced Due Diligence (EDD)
• EDD generally
• High risk third countries
• Simplified Due Diligence (SDD)
• Sanctions

Who should attend

Aimed at those working in accountancy practices and dealing with a range of client types, and is particularly relevant to those responsible for AML compliance.