My reading of the new legislation that CCAB practising members will not register with HMRC as they will still be governed by their professional body ie no change to the present position
Or am I missing something?
Clarification seems important!! Thanks
confused
Replies (7)
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CCAB members
Confused
Accountancy firms which are currently subject to monitoring by their professional body will continue to be monitored by that body. So, no change there.
Of course the MLR 2007 make other changes, some of which will impact on CCAB member firms. A few obvious examples are the need to confirm the ID of existing clients, the need for policies and procedures in the six areas itemised in Regulation 20, the risk-sensitive approach to CDD required by Reg 7, the need for ongoing monitoring of clients required by Reg 8 including, where necessary, consideration of the source of funds, the need for scrutiny of complex or unusually large transactions, the need for enhanced due diligence in the circumstances set out in Reg 14, etc.
Question for Euan
Euan
Perhaps I shouldn't dare ask, but I will.
Have you been on one of my courses? If so, how boring was it?
ACCA non practising certificate members
I have checked with ACCA the position of members who provide bookkeeping services without a practising certificate. They have advised me that their supervision under the Money Laundering regulations will only cover members who hold practising certificates. Members who provide services not requiring a practising certificate will therefore need to register with HMRC.
Jo
money laundering
I thought I had pretty much understood the new rules, however, the comment posted by MLRO support has caused some confusion. Is this saying that we have to confirm identities of all existing clients not just new ones?
Has anyone attend a training course related to this issue that they would be prepared to recommend?
Existing clients
Yes, Christine, we are now required to confirm the identity of existing clients, but not all at once. The identification requirements are not too onerous - have a look at page 47 of the draft CCAB guidance - so you will probably already have adequate evidence on your files for existing clients. You just need to take another copy of (say) a tax return notice and keep it specifically as evidence of identity.
Courses on MLR can be very, very boring. The draft guidance will tell you all you need to know.
Answer for David
Oops! Sorry! I didn't realise that you ran courses. I am sure your courses are the epitome of engaging enlightenment and can be thoroughly recommended. Is that a good enough plug for you?
I am puzzled by one thing. Do you run courses for accountants or just for the criminals that you often claim constitute the majority of your clients? Or do you not see any distinction between them?
That'll do nicely!
Euan
Thanks for the plug!
I have two businesses:-
Accounting Evidence Ltd - forensic accountants specialising in crime and proceeds of crime
MLRO Support Ltd - training and support services for professional firms in relation to money laundering
Hopefully you can see how these two fit together as far as I am concerned - both involve PoCA 2002 and related matters.
In the training sessions I do make use of war stories from my other business, like the one about the Vietnamese nail and manicure bar with an American sounding name and appalling records (and acting as a laundering operation for a cannabis factory in the North West of England). It makes it more interesting than droning on about which documents should, or should not, be accepted to confirm identity.
Also I am a money laundering nerd who actually enjoys reading money laundering regulations and criminal court judgments. If my excitement at these things gets across to my audience it can suspend the normal utter boredom for an hour or two.
I don't regard most accountants as criminals, but I do mention one who got 6 months!
David