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Anti Money Laundering

Formal Risk Assessment

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Hi All

I do bookkeeping part time from home. I have had the same clients for 11 years and I only have 3 clients. I have let my anti money launder supervision expire in June 2021. I didn't mean to. However I have since re-applied. Now HMRC are asking if I have a formal risk assessment and policies/procedure in place and trading without this is in place is a breach of the regulations. If I do not already have this in place I will need to recitify immediateley. I have to change the answer on the application form. I'm not sure how i find the application form let alone change it. 

Do you think they want to see this formal RA? I'm hoping some other people will know the answer.

Many thanks.

 

 

Replies (8)

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By SXGuy
17th Jul 2021 14:12

So put one in place now? As part of your aml requirements you should have risk assessments firm wide and client level, you should also have terms of service laid out in the form of an engagement letter

You can't alter the application form to my knowledge.

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By ZMBookkeeping
17th Jul 2021 14:18

HI
I've managed to find the application form.

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By I'msorryIhaven'taclue
17th Jul 2021 14:42

ICAS have very generously left their AML firm-wide risk assessment template lying around at https://www.icas.com/__data/assets/word_doc/0008/327626/ICAS-AML-Whole-F...

Download, and adapt answers to your business; score your firm's risks, press the print button, and presto!

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By ZMBookkeeping
17th Jul 2021 15:51

That's really helpful. Many thanks. Will do.

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By memyself-eye
17th Jul 2021 19:28

same clients?
Only 3?
11 years?
Formal risk assessment in place?
Policies and procedures?

You are probably a high risk, money laundering, Russian based (other domains are available) tax dodging agent, funnelling millions into offshore accounts or intoUK property/football teams (not Aston Villa though - my team)

HMRC are onto you - yeah right.

Mind you they can't find anyone else, so sleep easy.

Question : with 3 clients is it worth the hassle?

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Replying to memyself-eye:
paddle steamer
By DJKL
17th Jul 2021 22:26

No- it is not even worth all the hassle with 20-30. One of the reasons I gave up part time practice was the disproportionate time spent keeping abreast of ML regs, reviews, CPD etc, changes in tax/accounts etc, for the smaller practitioner this can readily be 20% of the total hours spent on the practice.

My solution was to become an employee with my largest client instead, the OP with just three clients might consider it worthwhile suggesting similar to his clients.

Remember if unconnected ,and previous fees individually below NI threshold no NI will be payable by employer or employee.

I just have an hourly rate applied to 10 hours per month (estimated 120 hours a year but not evenly spread) that gets processed each month via payroll, though will need to now get paid extra once a quarter for some new additional work.

Works fine for me, 21 hours a week doing my day job and on the extra job normally circa 2 hours a month, 15 hours each quarter and a blitz of 36 hours at year end, result, I have just spent the last three days in the sun , pretty much a four day weekend most weeks.

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Replying to memyself-eye:
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By ZMBookkeeping
18th Jul 2021 11:43

I'm now retiring!

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Replying to ZMBookkeeping:
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By memyself-eye
18th Jul 2021 18:27

I did - 2 months ago!
Now the business world is denied..DENIED! the wealth of my wisdom and omniscience.
For what?
the one hundred million to one chance that Joe Blogs, plumber, pillsr of the community, married with 2 kids, drives a 15 year old van - my client for 20 years is in fact a money launderer with properties across 'that' london.

Of it wasn't so hot I'd escape abroad on my boat.... (well ok to Nuneaton!)

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