Monitoring Compliance with Money Laundering Regulations

2. Monitoring visits and compliance with money laundering regulations

3. ACCA monitoring visits • Carried out to all firms in UK and Ireland which hold audit registration or Irish investment business authorisation • At least every six years, but may be only two or four years between visits, depending on standard of audit work or other breaches of ACCA’s regulations • Purpose of visit includes monitoring compliance with ACCA’s Global Practising Regulations • Includes section 3.8 of the Code of Ethics and Conduct on Money Laundering • As a Supervisory Body under the 2007 Regulations, ACCA is to commence ML monitoring of all other ACCA practising firms in the UK

4. Approach at visits • Opening meeting with practitioner or partners includes detailed questions on firm’s procedures and the MLRO’s knowledge of the requirements • Compliance officer review of the firm’s client and office bank accounts • Closing meeting and reporting of findings

5. Opening meeting

6. Questions on procedures (1) • Appointment of MLRO • Definition of ‘money laundering’ • Staff training & guidance • Controls to ensure anyone who suspects money laundering knows how to report it to MLRO • Identity of new clients & timing of procedure (commonly passport & utility bill)

7. Questions on procedures (2) • Knowledge of clients up to date? • Retention of records • Obligation if money laundering suspected (report without tipping off) • SOCA (or Garda Bureau of Fraud Investigation)

8. Review of firm’s bank accounts

9. Bank account review: purpose • Compliance with ACCA’s regulations • client money in office account (CEC 3.20) • investment business clients’ money (IIBRs) • clients’ insurance premiums (DPBRs) • actual or potential loss to client • Identify any instances of possible money laundering

10. Bank account review: procedure • All available accounts • Review of statements and accounting records • At least latest 12 months, may extend • Large, unusual, round sum or contra transactions • Date, amount, details, reason for transaction • Explanation and source of any evidence

11. Closing meeting

12. Discussion with practitioner(s) • Non-compliance with ACCA regulations: • Discussion of findings • Guidance for improvements and future action • May ask for further information & clarification • NOT any instances of possible money laundering

13. After the visit

14. Reporting • After peer review and discussion with Audit Compliance Manager, make online disclosure to SOCA of any suspicious transactions found (rare) • To the firm - confirmation of matters raised and discussed at closing meeting, and recommendations for future action • NOT any instances of possible money laundering

15. And finally… ACCA Quality Checked

16. ACCA Quality checked visits • Often in conjunction with monitoring visits • May be standalone or to firms which do not hold audit registration • New client procedures, including verifying identity • Report recommendations to firm • Permanent file for all clients - requirement to carry out customer due diligence (CDD) procedures on both existing and new clients under Money Laundering Regulations 2007