Accounting dilemmas: AML obligations
Sometimes in business, you can find that company ‘policy’ is more in the imagination of middle management then committed to paper. AAT’s head of professional standards Adam Williamson considers what happens when firms have not followed requirements to publish an anti-money laundering policy.
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Thanks for the query, David. As the regulations specifically require the firm records in relation to risk assessments to be 'up to date', AAT considers an annual review to be best practice. Of course, every time something of significance happens to the practice, this should also be an opportunity for review.
The big 4 along with large multi-national banks wash 99.9% of the worlds dirty money whilst taking legislators and government officials out to lunch to cut deals over the token fines they should pay when they're (infrequently) caught.
Us on the ground get threatened with disgrace and ruin because a subby might have pocketed some cash you don't know about.