1. ANTI MONEY LAUNDERING PRESENTATION
ICB / iAgSA
ANTI MONEY LAUNDERING
PRESENTATION

2. 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

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

4. 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

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

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

7. 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.

8. 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

9. 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.