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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 (18)

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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!)

Thanks (4)
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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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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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.

Thanks (4)
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 !

Thanks (1)
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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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