Tim Pinkney, Head of Compliance & Regulation, discusses key issues for the practitioner.



HM Treasury recently published the draft Money Laundering Regulations and the response to the Review of the Supervisory Regime.

You can find all of the relevant documents here and I urge you to read them and respond to the consultations:

The press release:

The consultation:

The supervisory regime response:

The draft regulations relate to the transposition of the 4th EM Money Laundering Directive and are required to be in place across the EU by no later than 27June 2017.

Have a look at the new CDD requirements and the need for Supervisors to implement Criminal Record checks on each beneficial owner, director and possibly front line staff on all its supervised population – i.e. on you.

There is to be a new Office for Professional Body AML Supervision (the office), to work with professional bodies to help, and ensure, compliance with the regulations. The office will be hosted by the Financial Conduct Authority (FCA). It will carry out this function separately from its existing supervisory work, and it will be funded through a new fee on professional body supervisors that the FCA will consult on in due course – talk about cutting red tape!

The new CDD requirements, criminal record checks on top of the new ‘Watchdog’ will inevitably have significant financial ramifications for firms and supervisors so I urge you to make your voice heard. I can assure you that AIA are working with all the other accountancy supervisors to make sure HM Treasury are aware of the strong depth of feeling and implications on the AML regime in the UK.


Have you seen the latest consultation on sanctions for late submission and late payment - again I urge you to look at this and respond to the consultation as the ‘soft touch’ approach appears to be diminishing.

You may also take heart in the recently published House of Lords Economic Affairs Committee Report on MTD which is demanding further delays and threshold adjustments. 


As always I would very much welcome any views you have on any of the above.