ICAEW visits and compliance with Money Laundering Regulations

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

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

3. 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)

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

5. 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

6. 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

7. 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