Monitoring visits
and compliance
with money
laundering
regulations
ACCA monitoring visits
•
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
Approach at 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
Opening
meeting
Questions on procedures (1)
•
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 (2)
•
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)
Review of firm’s
bank accounts
Bank account review: purpose
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: procedure
• 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
Closing meeting
Discussion with practitioner(s)
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
After the visit
Reporting
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
And finally…
ACCA Quality
Checked
ACCA Quality checked visits
• 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