Monitoring visits and compliance with money laundering regulations

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 ACCA monitoring visits

1.Opening meeting with practitioner or partners includes detailed questions on firm’s procedures and the MLRO’s knowledge of the requirements 2.Compliance officer review of the firm’s client and office bank accounts 3.Closing meeting and reporting of findings Approach at visits

Opening meeting

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) Questions on procedures (1)

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) Questions on procedures (2)

Review of firm’s bank accounts

1.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 2.Identify any instances of possible money laundering Bank account review: purpose

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 Bank account review: procedure

Closing meeting

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 Discussion with practitioner(s)

After the visit

1.After peer review and discussion with Audit Compliance Manager, make online disclosure to SOCA of any suspicious transactions found (rare) 2.To the firm - confirmation of matters raised and discussed at closing meeting, and recommendations for future action NOT any instances of possible money laundering Reporting

And finally… ACCA Quality Checked

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 ACCA Quality checked visits