ANTI MONEY LAUNDERING PRESENTATION ICB / iAgSA ANTI MONEY LAUNDERING PRESENTATION

The Institute of Certified Bookkeepers Aim To fulfil it’s role as a treasury appointed AML supervisor To ensure that all practicing members are properly protected from failing to comply To provide the best level of support to members

The ICB Inspection Process Telephone Call Letter/email confirming date and listing what will happen and what documents will be inspected An inspection may take 2 – 3 hours

During the ICB Inspection Completion of questionnaire Inspection of Policies and Procedures Statement Inspection of forms MLR7 (training record) Inspection of filing and storage Check AML Online

During the ICB Inspection Check copies of due diligence evidence Check record of annual review Agree actions required (if any) Complete Report Summary

Possible ICB Inspection Outcomes Fully Compliant Partially Compliant Non Compliant If a further inspection is needed it will be at member’s expense.

The Top Ten Errors found by ICB 1. Limited Company Due Diligence: Certificate of Incorporation or Companies House AR01 Personal ID for directors owning 25% or more of entity. 2. Driving Licence/Passport: Face to face recording – you must have seen the original document. If you have not met the client you must have a certified copy. 3. Storage: Files in a locked fireproof cabinet.

The Top Ten Errors found by ICB 4. Training every year and record keeping (MLR7) 5. Annual Review for AML Online – must recalculate before exiting 6. Over riding AML online risk assessment – proper explanation needed, but why bother to change it? 7. Clients not met face to face - enhanced due diligence needed and any copy evidence must be certified

The Top Ten Errors found by ICB 8. Unacceptable due diligence evidence – P60, mobile bills, 6-48 agents form or anything generated from own software. 9. Use of sub contractor bookkeepers – check who is their supervisor, they must do due diligence on you. 10. Sub contractor training – include in training initially on your systems, ongoing get details of their own training or record the training you give them.