Ian Lawrence
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Do I need to buy this AML system?

I am receiving cold calls to verify my clients

The new Fourth Money Laundering Directive (EU) 2015/849 was passed by the EU in June 2015 and will be implemented in the UK by June 2017.

I am receiving cold calls selling me new products to help comply with this.

Do I need to buy a new product?  I don't have any clients dealing in large cash quantities (no restaurants/tradesmen etc.) and I assess each client when I take them on.  If they are not low risk I don't take them on.  I don't currently document the risk assessments.  

It would be good to hear back from other accountants who must be receiving similar cold calls



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19th May 2017 16:54

Sadly, you need to be able to show that your manual is up to date.

I agree, though, that it's become a bit of an opportunity to rip off accountancy firms.

I used to use Practicegrowth, cost was around £60 - £80 every time there was an update, which might be less frequent than once a year.

The owner thoughtlessly retired, transferring his customer base to Mercia.

Mercia want £270 as an initial fee plus £105 every January.

Is it three times as good ? No significant difference, imho. It's pretty much the same collection of forms in a different wrapper.

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21st May 2017 11:07

The legislation does not require you to purchase a product. It requires you to, amongst others, know and understand your customers. How you choose to comply is upto you.

I have not yet had any cold calling on this subject, as far as I know. But then most cold callers I get barely get past introducing themselves let alone describe their product.

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to D V Fields
21st May 2017 20:34

The Money Laundering Regulations 2017 are not yet finalised, but are expected to come into force before the end of June.
You might want to look at Reg 19 in the draft regulations regarding the need for WRITTEN policies, controls and procedures

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to davidwinch
21st May 2017 21:07

Hi David
Does not change my view. You are required to comply; whether you choose documents etc. be typed, handwritten or held electronically you do not, as in the spirit of the original question, have to purchase a product to be compliant. Unless of course I've missed that subtlety.
Kind regards

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to D V Fields
22nd May 2017 07:20

Having a policy and writing one are, of course, two very different things.

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