AML Questionnaire is Excessive

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The latest AML compliance questionnaire consists of approximately 91 questions we must answer for each company and 70 questions we must answer for each individual. This is ridiculously onerous and expensive. As a small accountancy practice, how do we lodge a complaint?

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By Roland195
19th Oct 2023 10:41

Who provides this checklist & why do you continue to use it if you feel it is unsuitable?

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By Justin Bryant
19th Oct 2023 11:07

Ain't they all?

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By Tom+Cross
19th Oct 2023 11:18

As an accountant and tax adviser, with just over 50 years of experience, I have always worked within my limitations (able to complete work on time etc) but, more importantly, with clients which I have effectively "hand picked". My practice includes clients who are still with me, after 40 years or so and in some cases, I now act for the offspring of some original clients.
I therefore find some of the AMLR enquiries; highly intrusive and in many cases rude. I often add comments to the initial responses to ensure that I haven't omitted a reply, albeit that it may be blunt in its response.
All of us who are in the regulated professions and due to the regime of anti money laundering are now expected to trawl through; online and social media outlets to enable us to form an "opinion" for the AMLR assessments. It's akin to picking through the refuse, of my neighbours, or lurking in the shadows!
I do take AMLR seriously but, extremely reluctantly because, at the end of the day, my client; first and foremost, should enjoy my respect. And I hate to think, that I am an unpaid "copper".
I'm not sure; who you would complain to and I'm positive that there would be no outcome.

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Replying to Tom+Cross:
David Ross
By davidross
24th Oct 2023 10:17

You sound just like me! I won't get to 50 years until October 2025, but just celebrated 48 years since joining the Inland Revenue

I could not have put it better than you have

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Johny Fartpants Picture
By johnny fartpants
19th Oct 2023 12:09

Agreed. Money Laundering is becoming a nightmare. For client annual reviews we use our regulatory bdoy's pro-forma "client annual review checklist" (8 pages long per client) and the "anti-money laundering annual compliance review checklist" to check everything has been covered.

Then they email us an "Anti-money laundering (AML) annual firm return" to complete. The whole thing takes ages before you think about earning a living.

It would be interesting to see how much time most sole practitioners / small firms spent keeping on the good side of their accountant boards.

Not to mention the regular horror stories of how much the same accounting boards then penalise errant members as soon as anything goes wrong. Scary really.

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By Duggimon
19th Oct 2023 15:39

I have an AML questionnaire for our firm that I wrote. It has on it the contact details and identifying information of the client and has eight other questions. We've just had an AML visit from our regulatory body who approved our processes in full.

For clients with connections to weak money laundering regimes we have a separate more extensive questionnaire, but it's still not 70 questions.

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Replying to Duggimon:
Jane
By Jane Evans
24th Oct 2023 10:45

I have something similar for my sole person practice and it recently passed an ICAEW practice management review. I do have a very simple practice, with very few limited companies.

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David Winch
By David Winch
19th Oct 2023 16:01

A couple of points to be made.
Firstly there are a number of different supervisory bodies of accountants for AML Compliance (ICAEW/S/I, ACCA, AAT, ATT, CIMA, CIOT, ICB, IFA, IAB) and each of them has their own views on certain points and their own ways of inspecting their members - which makes it difficult to make comments of general application.
Secondly, my personal view is that AML/Onboarding software (either as a module within a wider software suite or as a standalone piece of software) can ease the burden of compliance and help improve the firm's consistency of compliance across its client base. Having said that, the use of such software is absolutely NOT mandatory.
To answer the OP's question about making a complaint, do you wish to complain specifically about the questionnaires you use or about the need to carry out Client Due Diligence and Risk Assessments?
David

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Replying to davidwinch:
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By johnjenkins
24th Oct 2023 10:09

David, you forget Customs and Excise.

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Replying to johnjenkins:
David Winch
By David Winch
24th Oct 2023 10:14

johnjenkins wrote:

David, you forget Customs and Excise.


Fair point!
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Replying to davidwinch:
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By johnjenkins
24th Oct 2023 10:43

I was going to expand and say that feedback from my colleague suggests that C/E aren't that worried about the detail as long as the basics are in place. He has a phone call every couple of years to check if anything has changed.

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Replying to johnjenkins:
David Winch
By David Winch
25th Oct 2023 09:04

johnjenkins wrote:

I was going to expand and say that feedback from my colleague suggests that C/E aren't that worried about the detail as long as the basics are in place. He has a phone call every couple of years to check if anything has changed.


I think HMRC are changing. They previously appeared to apply penalties to accountants only for failing to register on time. But now I see them (1) applying penalties for failing to fully comply with MLR requirements, and (2) refusing to register new applicants on various criteria (and cancelling agent codes).
So they are getting tougher!
David
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Replying to davidwinch:
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By johnjenkins
25th Oct 2023 09:27

My colleague did say that C/E changed the rules a few years ago. He had to undergo being a fit person etc. but he still got the phone call to check all was in order. It wouldn't matter anyway, he is someone that dots his i's and crosses his t's, so a visit would confirm. Perhaps the phone call was from someone who could pick that sort of thing up just by speaking to a person.

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Replying to johnjenkins:
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By Rgab1947
24th Oct 2023 11:42

And AIA

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Replying to Rgab1947:
David Winch
By David Winch
24th Oct 2023 23:50

Rgab1947 wrote:

And AIA


Yep!
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Replying to johnjenkins:
By JCresswellTax
26th Oct 2023 14:02

Probably because its not 2004.

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Replying to JCresswellTax:
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By johnjenkins
26th Oct 2023 15:45

I remember trying to read it but gave up. To me AML has always been a non starter. Those sort of rules will never catch the real criminals and as for Switzerland giving up its autonomy, dream on.

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All Paul Accountants in Leeds
By paulinleeds
24th Oct 2023 11:55

I have made up my own firm's AML checklist.

It probably has around 70/80 questions and is based on a Excel template Q&A that I found from the ACCA website on AML.

I have my checklist on Excel. I can prepopulate most of the answers on the template and then adjust the relevant answers if not applicable. It does save time.

Very few clients use cash, none sell WMD or sell chemical or nuclear weapons or are involved in proliferation finance.

All my questions and answers are review, but it takes less time to complete with most of the stupid questions already answered.

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Replying to paulinleeds:
David Winch
By David Winch
24th Oct 2023 23:22

paulinleeds wrote:

It probably has around 70/80 questions and is based on a Excel template Q&A that I found from the ACCA website on AML.


My personal view is that I am not a fan of EXCEL spreadsheets which use mathematical formulas to calculate AML risk, because I don't think AML risk assessment is a CALCULATION - I think it's a professional judgement.
David
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Replying to davidwinch:
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By Southwestbeancounter
25th Oct 2023 14:55

davidwinch wrote:

paulinleeds wrote:

It probably has around 70/80 questions and is based on a Excel template Q&A that I found from the ACCA website on AML.

My personal view is that I am not a fan of EXCEL spreadsheets which use mathematical formulas to calculate AML risk, because I don't think AML risk assessment is a CALCULATION - I think it's a professional judgement.
David

Your post effectively sums up the issues we have I think, David.

I too have downloaded the ACCA AML Excel template and I use it to show that I am 'ticking' all the relevant boxes despite the fact that is is extremely clunky and the layout, when printed, is hardly legible but I don't currently have the time to expend in reformatting it all.

We know our clients generally and I too have had many clients for over 30 years and take on very few new ones and you get a 'feel' for your clients, their affairs and their honesty and integrity etc.

I agree with you that an Excel spreadsheet is not necessarily the best way to answer the relevant AML questions and also not the best way to look at the associated risks of acting for a client etc but the ACCA, it appears, think it is acceptable and that is where the problem lies - they are my professional body and you are pretty much the most respected expert on the subject!

I try to cover my AML obligations from all angles - the Excel spreadsheet plus two other AML questionnaires, along with copies of the client's ID and also printouts of anything from social media etc to prove what their business does etc - probably total 'overkill' but all these massive AML fines recently have put the 'fear of god' into small practices!

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Replying to Southwestbeancounter:
David Winch
By David Winch
25th Oct 2023 15:11

I will send you a private message on here.
David

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Replying to Southwestbeancounter:
Slim
By Slim
26th Oct 2023 13:36

I also feel like this. AML is probably my no1 worry.

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Replying to Slim:
David Winch
By David Winch
26th Oct 2023 13:57

Slim wrote:

I also feel like this. AML is probably my no1 worry.


Absolutely, AML should not be your No 1 worry. If you have a system in place and some appropriate documentation, keeping sufficient AML records should be routine.
David
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Replying to davidwinch:
All Paul Accountants in Leeds
By paulinleeds
31st Oct 2023 23:29

Thanks David

I never said that I use the ACCA Excel template or any formulae for AML calculations of risk etc.

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