ICAEW visits and compliance with Money Laundering Regulations John O’Donnell Senior Reviewer QAD

ICAEW Institute methods of addressing Anti-Money Laundering Compliance Institute website Helpline Institute training courses 2007 CCAB guidance Visit process

ICAEW QAD visit process Discussion with appropriate personnel at the firm during the opening meeting Description of opening meeting process Initial discussions about the firm (to discuss AML issues in context of the firm’s clientbase, current and future – if relevant)

ICAEW QAD visit process Focus during opening meeting discussions on money laundering compliance: – Awareness of 3 rd AML Regulations – Training undertaken by principal/s and method cascaded to other principals and staff – Risk assessment and AML implications – Considerations applied to clientbase

ICAEW QAD onsite work Money Laundering implications considered in respect of reviews of: – bank accounts – fee notes – Commission statements – Training of principals and staff – Practice Assurance compliance review, if undertaken – Files reviewed during visit

ICAEW Issues from visits Consideration of clientbase pre-2004 Risk assessment of clients Acquisition of blocks of fees Customer Due Diligence Electronic identification Staff awareness in relation to transactions

ICAEW Issues from visits (continued) Politically exposed persons (PEPs) Reliance on other parties for identification Offshore clients Trust clients – beneficial owner Corporate clients – change of ownership