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AML Policies & Procedures- Can You Name It In One?

AML Policies & Procedures. Is It Humanly Possible To Have A Set Of These Written On 1 Piece Of Paper

Didn't find your answer?

If so, can someone send me a stencil.

Sick and tired of seeing professional stencils for this, that and whatever being too long and complex.

What's the legal minimum I can get away with. Only taking on low risk clients.

Replies (56)

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David Winch
By David Winch
05th Nov 2019 16:11

As the MLR 2017 run to 118 pages (before we consider 5MLD & 6MLD which will come into effect next year, probably) I think you will be lucky to get your firmwide risk assessment, individual client checklist, and policies & procedures on one page (unless you have a very large sheet of paper). Sorry!

David

P.S. We do have a one page individual client checklist in our firm, but all our clients are high risk which makes life simpler.

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By claudialowe
05th Nov 2019 16:21

Oh the irony of David's answer - the higher the risk, the less paperwork required...........

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By S-S
05th Nov 2019 16:27

I can do:
Policies and Procedures: 2 pages
Client Risk Assessment: 2 pages
Client Due Diligence Record: 2 pages

Happy to share them - you have a pm.

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Replying to S-S:
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By JoF
05th Nov 2019 16:28

Can you share with me too please S-S?

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Replying to S-S:
By penelope pitstop
05th Nov 2019 16:42

So you named it in 2!

Well done SS.

That is amazing!

Will be in touch shortly.

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Replying to S-S:
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By Silvie
08th Nov 2019 00:13

Hi. I would be very grateful if you could share those with me too. I have been send a survey to complete by my professional body and not sure if I have done the things right. Many thanks :)

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Replying to Silvie:
By 0098087
08th Nov 2019 10:49

Any chance of a share!

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Replying to S-S:
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By SLF
08th Nov 2019 09:44

Hi. I would be very grateful if you could share those with me too.
Many Thanks.

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Replying to S-S:
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By Practice Admin Monkey
08th Nov 2019 10:04

Any chance I could jump on the request wagon? Always keen to see what others have done that might be an improvement/simplification of the process.

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Replying to S-S:
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By david.james
08th Nov 2019 11:25

If I could join the share too that would be great.

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Replying to S-S:
By djn24
08th Nov 2019 11:50

Could I also have a copy too please?

Thank you.

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Replying to S-S:
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By smooreaccountancy
08th Nov 2019 12:21

Please could i also receive a copy if you are happy to keep sharing S-S.
Many thanks

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By Charlie Carne
08th Nov 2019 13:01

You've started a bandwagon here. May I see a copy, please? Thank you.

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Replying to S-S:
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By kuba40
08th Nov 2019 13:02

Hi S-S
Would you be able to share your AML policies with me too, please Thanks

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Replying to S-S:
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By Cathy Milligan
08th Nov 2019 13:24

Hi S-S,
Could I be included in the share too please? :-)

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Replying to S-S:
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By Teesside
08th Nov 2019 14:24

Hi S-S
Would you please also consider sharing with me too. Many thanks.

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Replying to S-S:
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By AJLang
08th Nov 2019 15:02

I would be keen to have a copy as well if possible please.

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Replying to S-S:
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By Henri-Hound
08th Nov 2019 15:49

Hi could I also request a copy if you don't mind too much.

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Replying to S-S:
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By davidjlynch
09th Nov 2019 05:19

Please share with me, thx

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Replying to S-S:
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By ashvani jaitly
09th Nov 2019 18:04

S-S wrote:

I can do:
Policies and Procedures: 2 pages
Client Risk Assessment: 2 pages
Client Due Diligence Record: 2 pages

Happy to share them - you have a pm.

Shall be grateful if you can share them with me as well! Many thanks.

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Replying to S-S:
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By susieq
10th Nov 2019 11:18

HI S-S

Bit late in the day compared to others but could i have a copy too please? Not sure what I've done would be sufficient so be good to see this. TIA

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Replying to S-S:
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By tladirect
10th Nov 2019 14:37

S-S wrote:

I can do:
Policies and Procedures: 2 pages
Client Risk Assessment: 2 pages
Client Due Diligence Record: 2 pages

Happy to share them - you have a pm.

I don’t believe this!

Please pm me a copy without delay so that I can vouch for your credibility!

(...and thanks!)

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Replying to S-S:
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By andy1
11th Nov 2019 21:13

I'd really appreciate it if you could also share-I have also received the dreaded 6th December summons

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Replying to S-S:
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By davidjlynch
12th Nov 2019 23:03

what do you mean by 'pm'?

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By selbygray
13th Nov 2019 09:15

Yes please - what do you need to send them?

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Replying to S-S:
Sparkly Orange
By Sparkly
14th Nov 2019 14:34

When you have a chance after dealing with the already huge number of requests, could I possibly have a copy of these too? Much appreciated, thank you

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Replying to S-S:
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By KH
15th Nov 2019 14:43

Yes please, me too ... rather late in the day, I know, but have been too busy to look at the posts recently ... thanks in advance ... KH

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Replying to S-S:
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By evie
21st Nov 2019 13:09

Please can you send me a copy of this too.
Be so grateful.
Thanks

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Replying to S-S:
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By davidjlynch
26th Nov 2019 13:35

please advise what you mean by having a pm.

thx

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Replying to S-S:
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By davidjlynch
26th Nov 2019 23:36

what do you need from me to obtain your 6 pages

many thanks

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By JoF
05th Nov 2019 16:27

Does anyone have a scooby what the level of money laundering was prior to such regs versus now?

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Replying to JoF:
David Winch
By David Winch
05th Nov 2019 16:46

JoF wrote:

Does anyone have a scooby what the level of money laundering was prior to such regs versus now?

The goal posts were moved very considerable when the Proceeds of Crime Act 2002 & MLR 2003 were introduced (revoking the MLR 1993). Because the legislation introduced a new & very much wider definition of "money laundering" (so that it need not involve either "money" or "laundering") no sensible comparisons can be made. Sorry (again)!
David

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Replying to davidwinch:
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By JoF
05th Nov 2019 16:57

Oh dont apologise David. It was just a random thought that popped into my head, which is probably where it should have stayed.

I do recall the changes in the eary 2000s as I was heavily involved in sorting out issues at Corporate level for one of the major banks. Interesting how things have changed since then.

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By ireallyshouldknowthisbut
05th Nov 2019 16:49

The longer these things are, the less likely anyone will read or act on them.

I wonder if anyone has actually worked out a cost/benefit analysis on this. Ie how much time and cost we all put in to deal with this, and how much (if any) Money Laundering has been spotted and stopped.

Im guessing the first number is much larger than the second one.

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Replying to ireallyshouldknowthisbut:
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By Roland195
05th Nov 2019 16:56

Great minds

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By Roland195
05th Nov 2019 16:55

"The longer a checklist, the more impressive it appears to those that oversee it but the less use it will be for any practical purpose"

Roland, Accountingweb 2019

I would argue that a short, to the point checklist with points relevant to the actual client, properly completed should mean more than 12 pages of irrelevant drivel with N/A (Non applicable, Not Attempted , Not Arsed?) but I imagine I would be the only one.

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By sonoftwosheds
05th Nov 2019 17:41

Hi SS

Can I be cheeky and have a copy too? Will send you a message
thanks

Julie

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By penelope pitstop
07th Nov 2019 03:37

Here's a concentrated starter for one. I am sure many/all of you will be able to "punch holes in it". Please feel free to do so. Please also feel free to add your own clauses when you post your response. Hopefully, by your additions (or subtractions) it may morph into something of use.

If the AML "police" arrive on your doorstep, hopefully it may just "save your skin". (By the way, is there such a thing as an illegal AML Policies and Procedures document?)

The following version came to me in a dream without referring to any paperwork. It is designed for a sole trader with one employee (maybe a spouse) and taking on only low risk clients where ANY suspicious activity (hopefully none) is IMMEDIATELY reported to the NCA. It is also designed to close your doors to any risky clients.

By the way, almost all of my clients are referrals from existing clients. So here goes (fits on one A4-sized piece of paper!):

Anti-Money Laundering Policies & Procedures for (insert business name)
Accountant & Tax Adviser

AML Policies

1) It is not the policy of the business to take on medium risk clients.

2) It is not the policy of the business to take on high risk clients.

3) It is the policy of the business to take on low risk clients only.

4) If a low risk client becomes medium risk due to a change in circumstances the business may decide to cease acting for that client.

5) If a low or medium risk client becomes high risk for whatever reason the business will immediately cease acting for that client.

6) The business has no interest in taking on any clients which could potentially be involved in money laundering or terrorist activity.

7) The business will actively take action to turn away potentially medium and high risk clients.

8) If a prospective new client is not known to an existing client then the business will not engage the prospective new client unless it can be proved that the prospective new client can be classed as low risk.

AML Procedures

1) (Proprietor's name) is the designated Money Laundering Reporting Officer (MLRO) for the business.

2) Should the MLRO become aware of any suspicious transactions then they are to report those suspicions to the National Crime Agency (NCA) or any successor entity as soon as possible.

3) Should the employee of (proprietor/business name) become aware of any suspicious transactions then he is to report those suspicions to the MLRO immediately.

..................................................................Mrs X Y Zzzzzz (Proprietor and MLRO)

...................................................................Date

...................................................................Mr A B Cccccc (Sole employee)

...................................................................Date

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Replying to penelope pitstop:
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By Malcolm McFarlin
08th Nov 2019 12:44

I think the issue you have with your suggestion -is how do you know all of your clients are 'low risk' ? You have to apply a risk assessment to each of your clients rather than by using a tick box approach. For instance a client whom you have never met may represent a higher risk to your business than one you have met. A client who handles large amounts of cash may represent a higher risk than one who doesn't. You need to identify the beneficial owner of a company who could be different from the director. You have to provide an explanation as to why you consider your clients are all low risk. I have a separate 'Risk Assessment' profile which is reviewed annually , a MLR Policy & Procedures and individual client due diligence forms. I had a MLR visit in 2015 by HMRC and they were happy with the systems I had in place.

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Replying to Malcolm McFarlin:
By penelope pitstop
08th Nov 2019 13:43

Thanks for your input.

The situation I now have is that I have reached "tipping point" with my business.

At long last I can either accept or decline new business.

So, my new, draft, ultra-concise and ultra-simple AML Policies and Procedures is this:

"If a client represents an AML risk to my business, I don't want to know you.

If you are involved in anything suspicious, I will report you.

No ifs, no ands, no buts".

What's there not to like about this.

Much simpler than the anti-AML library/TOME which my previous Chartered Accountant employer had (which was never read by any employee).

(By the way, I already have a separate checklist to determine a prospective new client's risk profile/identity/using an intermediary etc.)

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Replying to Malcolm McFarlin:
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By S-S
08th Nov 2019 13:46

PP's response is tongue in cheek but she covers the points you make in sections 1 through 4.
You're not obliged to take on high risk clients - I had a telephone interview with HMRC a few years ago which included a questioning along the lines of:
HMRC "What would you do if approached by a potential client from overseas?"
Me "I'd decline the approach."
HMRC "No, but what if they made you a really good financial offer?"
Me "I'd still decline the approach."
HMRC "No, but what if you wanted to take them on?
Me "I wouldn't..."
HMRC "But if you did..."
Eventually I felt sorry for the seemingly fairly junior and inexperienced interrogator who was obviously working from a script and gave the answer they craved, even though it was never going to happen in reality, the box was ticked and we both moved on with our lives.

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Replying to Malcolm McFarlin:
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By S-S
08th Nov 2019 13:46

PP's response is tongue in cheek but she covers the points you make in sections 1 through 4.
You're not obliged to take on high risk clients - I had a telephone interview with HMRC a few years ago which included questioning along the lines of:
HMRC "What would you do if approached by a potential client from overseas?"
Me "I'd decline the approach."
HMRC "No, but what if they made you a really good financial offer?"
Me "I'd still decline the approach."
HMRC "No, but what if you wanted to take them on?
Me "I wouldn't..."
HMRC "But if you did..."
Eventually I felt sorry for the seemingly fairly junior and inexperienced interrogator who was obviously working from a script and gave the answer they craved, even though it was never going to happen in reality, the box was ticked and we both moved on with our lives.

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Replying to penelope pitstop:
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By andy1
11th Nov 2019 21:16

Thanks for sharing Penelope!
I'm so glad I found this page- good to have safety in numbers

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By Cornish Clare
08th Nov 2019 13:11

Have sent you a PM S-S

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By James
12th Nov 2019 10:29

S-S

Can you send me a copy as well please, I am not very up with this so how do you go about it i.e. what do you want from me.

james

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By MILLY1
12th Nov 2019 10:31

Morning S-S
Can I please have a copy as well?

Thanks

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By penelope pitstop
12th Nov 2019 11:53

Some of the replies so far reveal how many are overwhelmed by the Anti-Money Laundering legislation and by the sheer mass of vague information on the subject.

Many accountants, especially the smaller ones drowning in their own workloads, just cannot get concise, specific, digestible guidance on this subject.

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Replying to penelope pitstop:
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By andy1
12th Nov 2019 21:20

You have hit the nail on the head there Penelope

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By andy1
14th Nov 2019 10:02

Has anyone completed the online Survey yet?

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Replying to andy1:
By penelope pitstop
14th Nov 2019 17:03

What online Survey? The Survey, or a survey.

Have not seen it advertised on Sky TV or BBC yet!

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