Have you had an AML ACCA review before?

Practitioners experiences with ACCA AML reviews

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Hi all,

Our firm has been selected for an AML review with ACCA. We will be having a review call with an ACCA supervisor soon. They have asked for information in preparation for the meeting such as:

  1. An organisation chart (including roles of all employees)
  2. A list of the firm's clients for the last 2 years which must include their risk rating, type of industry and location

I wanted to know the experiences of other ACCA regulated practitioners who have had these checks and the further work they had to complete after the meeting. Feel free to private message me if you are not comfortable replying to this thread.

Thank you.

Replies (37)

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By Max Maxwell
06th May 2021 19:12

Yes, we had one in 2019 and it was a pain in the a**!

They will send you a list of things that they will expect when they visit you and if they are not satisfied with your procedures and record-keeping, they will not offer any assistance or guidance, but instead will tell you to go read the legislation!

We had everything documented, procedures and records, but they were not satisfied with our documented procedures but would not spell out that that is what they were unhappy about.

Every time we sent them revised procedures, their standard reply was it was not adequate without any helpful advice as to what was wrong or needed amendment, and all correspondence ended with a para saying they needed a response within a few days and if one was not sent by the due date, we would be referred to the disciplinary committee!

Pure bullying tactics, in my opinion!

In the end, we had to go to a specialist AML organisation to seek their assistance, and it turned out that we just needed to brush up on our procedures.

If you want a list of the details they requested before the AML inspection visit, please drop me a private message.

Best of Luck with your inspection (you will need it!)

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Replying to Max Maxwell:
By Moonbeam
07th May 2021 08:04

This is horrifying. If this is their attitude when you'd spent time and effort to get it right from the start I would agree that it's bullying tactics.
Presumably the inspector went home feeling very smug.
I think we should be asking our own bodies what their methods are in these circumstances.

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Replying to Max Maxwell:
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By Rgab1947
11th May 2021 10:34

"In the end, we had to go to a specialist AML organisation to seek their assistance, and it turned out that we just needed to brush up on our procedures"

Hopefully not one recommended by them.

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Replying to Max Maxwell:
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By 525252
11th May 2021 10:53

This is Spooky because it mirrors our experience in most aspects !!!! they didn't like what we had and where totally unhelpful as to what we should do and likewise we had to get a 3rd party specialist involved

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Replying to 525252:
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By Hugo Fair
11th May 2021 11:33

Spooky indeed ... it's almost as though they had a vested interest in assisting those 3rd-party specialists (who may spend money via advertising or sponsorship with the Institute/Association)?

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Replying to Hugo Fair:
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By Paul Crowley
11th May 2021 12:07

Thinking about it now,
I remember after the bad visit getting emails from people wanting to sell their help.

I think I was also given a contact by the evil invader

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Replying to Max Maxwell:
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By Paul Crowley
11th May 2021 12:02

That shocks me

In the days of being a statutory auditor the reputation was that ICAEW was a bit fierce and ACCA being very helpful and supportive

On our various visits with ICAEW we only ever had one deliberately destructive person arrive. A former big 4 employee that had been let go and had never been in practice or a decision maker.

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Replying to Max Maxwell:
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By SouthCoastAcc
05th Jan 2022 17:17

I know it is an old thread but sadly this post sums it up perfectly for me.

They are zero help whatsoever.

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David Ross
By davidross
11th May 2021 09:38

I have suffered at the hands of LAUTRO 30 years ago, and a friend pointed out that all regulators are the same (he was in atomic energy). "Ve ask the qvestions" seems to be their mantra.

No idea why - honey gets better results than vinegar.

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By steveoneill
11th May 2021 09:48

Have helped a few firms recently who have failed there ACCA AML compliance visit, I have an ICAEW case at the moment. The main areas they are failing on apart from weak policies and procedures as a whole are
1. The firm wide risk assessment with mitigating policies
2. PEP's as part of your client onboarding
3. Reporting discrepancies in PSC register
4. AML training of staff
5. Staff appraisals and BOOM's
6. Regular reviews of the policies and procedures
7. SAR's reporting by staff and SAR records, and
8. ongoing risk assessments of clients
These are the common failures as they are easy for the examiner to pick up on weak or non-existent policies. Good luck

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Replying to steveoneill:
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By Rgab1947
11th May 2021 10:35

Jobs for pals.

And all because the cops and HMRC cant or will not do their job.

Retiring soon so I do not have to be an unpaid cop anymore. Oh joy!

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Replying to steveoneill:
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By I'msorryIhaven'taclue
09th Feb 2023 09:25

What I'd add to Steve's post based on my experience is to document everything.

It's not enough to Know Your Clients well enough to be confident that they're not terrorists or money launderers: you have to record every CDD/EDD step you take and document every review, outcome or decision (yes, yes... even if the client is your next door neighbour or your favourite uncle). Skimp on the form-filling and you'll earn yourself a bad house-point!

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Replying to I'msorryIhaven'taclue:
By Moonbeam
09th Feb 2023 09:32

I just tick a box on a bought in MLR form that client is still low risk every year. (All my clients are low risk).
Are you saying I need to write an essay about why they're low risk every year?

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Replying to Moonbeam:
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By aandaaccounting
09th Feb 2023 09:42

Ohh yes...and have a firm procedure
I have just appointed external firm as ICAEW insisted and its very indepth even though I am a sole practitioner. Just simply ticking boxes and checking ID's not sufficient

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Replying to aandaaccounting:
By Moonbeam
09th Feb 2023 10:28

So, at the end of the accounting year, would you write a precis of significant changes to the business, and what else?
Many of my clients don't do anything different each year.

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Replying to Moonbeam:
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By norstar
09th Feb 2023 10:35

According to the ACCA AML office, your clients can't be low risk unless they're a bank or financial institution.

I pointed out that Gladys who I have known for 30 years and only has pension income and lives on her own in a house, probably isn't "medium risk" but according to them that's not true. They basically forced me to "reassess" my client base and make everyone medium or high risk.

For the significant changes, our workflow has a stage in each job to review the KYC info and AML evidence on file - you'd do changes there.

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Replying to norstar:
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By I'msorryIhaven'taclue
09th Feb 2023 13:04

norstar wrote:

According to the ACCA AML office, your clients can't be low risk unless they're a bank or financial institution.

Or a local corporation or some other government or local government orgainisation (don't take that verbatim, just take the general drift that the chances of any of your clients being classified as being low risk are, well, low. So no SDD for you.)

The objective seems to me to classify your clients as medium risk (so that you perform regular CDD). If they are classified as high risk (EDD) then keep a-gathering information and a-verifying it until you achieve a medium risk result. Then go write it all up - having an audit trail seems to be an absolutely essential requirement. Woe betide anyone who doesn't!

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Replying to I'msorryIhaven'taclue:
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By norstar
17th Mar 2023 09:36

I think you're spot on with this.

The ironic thing is that our workflow reviews CDD every year anyway - more than appropriate for a medium risk client. But they got their knickers in a twist that we had classified such clients as low risk.

The problem with the ACCA that I've found - and the same applies in Audit reviews - is that they simply believe that their opinion on an area of contention is the only valid opinion.

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Replying to norstar:
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By BryanS1958
16th Feb 2023 10:53

ACCA obviously are not aware of HSBC's alleged money laundering connections in Mexico, etc.

How many money laundering connections has Gladys got to make her higher risk than HSBC?

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Replying to norstar:
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By BryanS1958
16th Feb 2023 11:05

On what basis did the ACCA decide that Gladys wasn't low risk?

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Replying to BryanS1958:
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By Tax Dragon
17th Mar 2023 07:06

'Low risk' doesn't really mean anything. There are people (Gladys probably being one such) for whom standard due diligence is sufficient. For other people you have to undertake additional precautions. And then there are those you cannot act for.

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Replying to Tax Dragon:
David Winch
By David Winch
17th Mar 2023 09:55

I think the issue here is that regulators have a view that certain types of client - and only those types of client - are "low risk", for example, local authorities.
Is Gladys a local authority? No. Therefore she is not low risk.
I would describe Gladys as "normal risk" or, if you prefer, medium risk. So you do in terms of CDD what you do with the vast majority of your clients. If you classify Gladys in this way and do the standard CDD your regulator will be perfectly happy.
(We could debate whether local authorities actually are "low risk" in terms of the risks of corrupt councillors or employees or the risks of frauds being conducted in relation to local authority expenditure - but let's not go there!)
David

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By johnjenkins
11th May 2021 10:03

Yet scammers and drug lords bypass all these regulations. Seems odd to me.

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Replying to johnjenkins:
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By Rgab1947
11th May 2021 10:36

Helped by the very large banks.

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By Max Maxwell
11th May 2021 11:53

In my opinion, if ACCA were to be inspected by another independent organisation for their own AML policies and procedures, they would NOT pass the AML inspection!

Basically, ACCA are a bunch of goons and bullies, who live in their ivory towers! All they are concerned with is collecting fees and increasing their membership base, here and around the world without providing support or guidance.

ACCA has become a money-making business because they realise that many overseas candidates are looking for a UK-based qualification that will help them in their career.

A friend who is a member of ICEAW told me that he had a similar inspection, but his inspection was undertaken in a really professional manner with his regulatory body providing them positive guidance, feedback and helping them comply with the AML regulations.

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Replying to Max Maxwell:
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By Paul Crowley
11th May 2021 12:15

Re your friend
That mirrors my recent experience
No friction and looking to be helpful and productive.

Critical is having bought a system, and demonstrating that it is in use.
NEVER try to create your own systems. Those go out of date so quickly.

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Replying to Max Maxwell:
David Winch
By David Winch
11th May 2021 13:36

Max Maxwell wrote:

In my opinion, if ACCA were to be inspected by another independent organisation for their own AML policies and procedures, they would NOT pass the AML inspection!

May I suggest you google OPBAS !

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By BryanS1958
11th May 2021 13:10

I had one from ICAEW and, to be fair, for a change they were quite reasonable and sensible.

I am a sole practitioner and all my clients are from referrals, so normally I have some background on them. Most manuals, etc are not designed for my circumstances and are overkill. Just box ticking exercises, with no common sense involved.

I agree that the only people who follow AML rules are honest citizens; criminals will just find a way around them. If the client is HMRC registered, bank registered, etc they should already have had their ID and address checked, so it shouldn't be necessary for accountants to check yet again! Possibly accountants with client accounts should have a few more regulatory hoops, but other accountants with routine, non-cash clients should have a lighter regulatory touch.

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By norstar
27th Jul 2021 09:18

My turn with one of these now! My issue with all this is that a fellow local ACCA practitioner thinks it's hilarious that I've had 7 or 8 visits over the past 16 years when he hasn't seen the ACCA once in over 20 years (which he's extremely relieved about)... It's not fair and anti-competitive.

If anyone has any feedback from these visits, I'd be grateful as it's the first I've come across.

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Replying to norstar:
By Moonbeam
27th Jul 2021 09:23

Good luck. Let us know how it goes.

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By aandaaccounting
08th Feb 2023 09:52

Does anyone have details of a specialist AML organization. I had an ICAEW review and they need me to get an external AML compliance review. I have searched online but seems all just provide templates and ongoing client checking but nothing what ICAEW are asking.
Thank you

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Replying to aandaaccounting:
David Winch
By David Winch
08th Feb 2023 10:02

I will send you a private message.
David

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By BryanS1958
16th Feb 2023 10:48

It is telling that it is necessary to invent things to write about clients, pretend they are higher risk than they are, etc.

The AML rules are a farce. Most accountants do not hold client money and where there are substantial transactions they would have normally been vetted by banks, solicitors, etc. I know whether one of my clients has done something that I would not expect, if it happens I would check it. I don't need to write an essay about each client's risk profile, it achieves nothing, aside from maybe keeping a jobsworth happy.

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By [email protected]
16th Mar 2023 20:11

Hi,
Can some one suggest an aml specialist firm, which they have used for the fail aml compliance check by the body.

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Replying to [email protected]:
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By Hugo Fair
16th Mar 2023 23:15

I'd imagine there are a limitless number of people prepared to take your money in return for assisting you to "fail aml compliance check"!

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Replying to Wanderer:
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By [email protected]
17th Mar 2023 09:41

Thanks I have contacted him already

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