Member Since: 13th Mar 2020
Julia Penny is the principal of JS Penny Ltd which provides technical and training consulting on anti-money laundering procedures, auditing and financial reporting. Julia is a member of ICAEW Board and Council, chair of the ICAEW Ethics Advisory Committee and past chair of the ICAEW Technical Advisory Committee.
Director JS Penny Ltd
1st Nov 2021
Having read some of the comments below I can understand that some think this area is a difficult one to deal with, as it does indeed require a consideration of whether an individual who is regulated for money laundering purposes (so someone providing accounting services in a practice for example) is suspicious (or has knowledge) of money laundering. It is a judgement and it doesn't require evidence that would stand up in a court (that would come later if the matter is pursued). Just because someone else has suggested wrongdoing, this doesn't automatically mean that you are suspicious, as it will depend on the circumstances, but it might make you suspicious. Bear in mind, that articles are only quite short explanations of key points and are designed to supplement the CPD that you will be doing.
9th Jul 2021
Great article Lucy - thank you for sharing.
10th Jun 2021
In the context of a practice assurance visit it means that instead of someone turning up at the office, they asked for relevant documents to be uploaded onto a secure portal and then had email/phone exchanges regarding extra information or discussions that were needed.
10th Jun 2021
Interesting point. Certainly anecdotally there have been plenty of issues with COVID related grants. I am not sure that the question asked was specific enough to know what the answer was. I wonder what others have experienced?
25th Mar 2020
You're right that all of these are problematic. ICAEW has raised them in its response to the consultation and hopefully there will be additional clarity and more sensible deadlines, especially for those trusts such as will trusts and ones where those creating the trust will have no idea of the need to register until they contact their accountant at the end of the tax year.
Some trusts are more obviously "in" the regime than others, so a certain amount of planning might be possible. At the moment there will no doubt be more pressing issues.