Accountancy firms have had to comply with anti-money laundering legislation since 2004. During that time the requirements have changed several times, most recently in 2017 with the introduction of the 2017 Money Laundering Regulations.
Although many firms have the required anti-money laundering (AML) policies and procedures in place, the level of compliance varies widely. Both ICAEW and Mercia incorporating SWAT regularly come across firms that have AML issues or a lack of understanding in the following areas:
It’s vital to have the correct systems in place and to give staff regular AML updates and training to make sure your firm is complying with the latest regulations. ICAEW has partnered with Mercia incorporating SWAT to develop the ICAEW Anti-Money Laundering Service to raise firms’ awareness of their AML obligations and help them implement correct procedures.
ICAEW has 13,000 practising firms, as well as being a supervisory body responsible for ensuring AML compliance by its members. As such it has considerable insight into the AML compliance issues that firms encounter. Mercia incorporating SWAT is the largest independent provider of compliance and quality reviews in the UK and has an enviable reputation for providing AML compliance products and services.
Our AML service will give your firm the guidance and practical tools you need to comply with the 2017 Money Laundering regulations. You’ll also have online access to a range of practical documentation, helpsheets and training, tailored specifically to the size of your firm and the profile of your clients.
Although the Anti Money Laundering Service has been designed in conjunction with ICAEW, it is suitable for accountancy practices affiliated to any professional accountancy body.
Aimed at sole practitioners with no staff or subcontractors (or just one or two) with a limited variety of clients, all of whom operate purely within the UK.
Aimed at firms with staff dealing with a more varied client portfolio, all of whom operate purely within the UK.
Supporting firms of any size who have UK or overseas clients, or UK clients with overseas connections.
|Suitable for||Sole practitioners with no staff or subcontractors (or just one or two) with a limited variety of clients, all of whom operate purely within the UK.||Firms with staff dealing with a more varied client portfolio, all of whom operate purely within the UK.||Firms of any size who have UK or overseas clients, or UK clients with overseas connections.|
£105 per annum*
£215 per annum*
£595 per annum*
|UK-based clients with UK customers who operate purely in the UK||Covered||Covered||Covered|
|Overseas clients or UK clients with overseas connections (customers, suppliers, branches, investors etc)||Covered|
|Number of staff / subcontractors||Maximum of 2||No limit||No limit|
Client types covered (with relevant customer due diligence forms)
Sole-traders / Individuals
|UK only||UK only||Full|
|Professional firms subject to ML Regulations||UK only||Full|
|Other partnerships and unincorporated businesses||UK only||UK only||Full|
|Unlisted limited companies||UK only||UK only||Full|
|Charities||UK only||UK only||Full|
|Church bodies and places of worship||UK only||Full|
|Clubs and societies||UK only||Full|
|FSA / FCA(1) authorised entities||UK only||Full|
|Trusts or foundations||UK only||Full|
|UK public sector bodies, government departments, councils and other local authorities||Full|
|Non-UK public sector bodies, government departments, councils and other local authorities||Full|
Other documentation included
Example AML policies and procedures
|Simplified version||UK only||Full|
|Client risk assessment flowchart||Simplified version||UK only|
|Client risk assessment - for individuals||Full|
|Client risk assessment - for entities||Full|
|KYC forms with annual review - for individuals||UK only||UK only||Full|
|KYC forms with annual review - for entities||UK only||UK only||Full|
|Annual declaration form by staff||Full||Full|
|Annual compliance review form||Simplified version||More detailed||Full|
|Suspicious Activity Report||Full||Full||Full|
|Detailed Annual Review Form - Individual||Full||Full||Full|
|Detailed Annual Review Form - Entity||Full||Full||Full|
|2017 Money Laundering Regulations Checklist detailing the changes required to your policies & procedures||Full||Full||Full|
|Policies and procedures||UK only||Full|
|Customer due diligence||Summary|
|Customer due diligence - introduction||Full||Full|
|Customer due diligence – entities||UK only||Full|
|Customer due diligence – directors, trustees etc||Full||Full|
|Customer due diligence – beneficial owners||UK only||Full|
|Customer due diligence – simplified due diligence||Full|
|Customer due diligence – electronic verification||Full|
|Customer due diligence – PEPs and sanctions checks||Full|
|Customer due diligence – reliance on third parties||Full|
|Customer due diligence – certified copies||UK only||UK only||Full|
|Ongoing monitoring||UK only||UK only||Full|
|Duty to report||UK only||UK only||Full|
|Obtaining consent||Routine work only||Routine work only||Full|
|Exemption from reporting in privileged circumstances||Full||Full||Full|
|Tipping off||UK only||UK only||Full|
|AML Training||Routine work only||Full|
|Equivalent jurisdictions for money laundering purposes||Full|
|High risk jurisdictions for money laundering and anti-terrorist financing||Full|
|Criminal Finance Act||Full||Full||Full|
|BOOMS and DBS Checks||Full||Full||Full|
|What makes a good SARs Report and SARs Glossary Code||Full||Full||Full|
|Online introductory training||Access for single person only. Additional persons are charged separately||Unlimited access||Unlimited access|
|Access to SWAT UK's Bribery Act 2010 online course||Access for single person only. Additional persons are charged separately||Unlimited access||Unlimited access|
|Live annual anti-money laundering update webinar||May be purchased separately||May be purchased separately||Unlimited access|
|Online recording of annual anti-money laundering update webinar||May be purchased separately||May be purchased separately||Unlimited access|
|Online recording of specialist anti-money laundering training on:
||May be purchased separately||May be purchased separately||May be purchased separately|
|Monthly newswire of key changes and topical information||Included||Included||Included|
(1) On 1 April 2013 the FSA (Financial Services Authority) became the FCA (Financial Conduct Authority)
*Prices exclude VAT and are payable in full at the start of your subscription period. Prices are valid until 31 December 2018. The ICAEW Anti-Money Laundering Service is a 12 month online subscription package. Prices are per firm per year and entitle your firm to any updates which are made to your Anti-Money Laundering System throughout the course of your 12 month subscription. Subscribers will be notified when any documentation has been added or updated within your Anti-Money Laundering System.
Online specialist anti money laundering training - In addition to our three web-based systems, the Service also provides specialist AML training and systems covering the areas of tax consultancy, corporate finance, litigation support and insolvency
These recorded online courses are ideal for new members of staff joining your firm or as refresher training for existing members of staff.
This introductory AML course for accountants and tax advisers is available to watch right now.
N.B. This course is an introductory course and so does not cover more complicated issues, nor does it specifically refer to the differences between the 2007 and 2017 regulations.
The course will provide you with an overview of the various offences that have been created by the Bribery Act, and review the statutory guidance issued by the Department of Justice. This will help you to understand what policies and procedures you and your clients will need to put in place and how the Bribery Act interacts with your obligations under the Money Laundering Regulations 2007.
The course will include:
These live webinars range from 30 to 60 minutes, depending on the complexity of the subject. They will all be recorded and available to watch online after the live event.
This course will include:
We were delighted with the logical approach adopted by the ICAEW's AML service, both in terms of standard documentation and supporting help sheets and guidance. We found it simple to introduce across the firm, easy to understand and most importantly, easy to keep up to date
ICAEW AML Standard System
Read Milburn - Nick Liley, Partner
The helpsheets, coupled with unlimited access to online training, supplemented our existing AML arrangements extremely well.
Grant Thornton - Roy Welsby, Partner & MLRO
The AML system is easy to follow and simple to use. The monthly newsletter is an excellent way of maintaining AML awareness as well as keeping up to date. The training webinars are excellentto keep the whole firm up to date and cost effective. The help sheets are also very easy to use.
ICAEW AML Complete System
Bartfields (UK) Limited - Gavin Bell, Director