Those of you who work within a practice or run their own accounting practice will have struggled to miss the new Money Laundering Regulations (MLR 2017) that arrived last summer.
There are those of you who are accepting of the regulations and although you may not be absolutely in love with Anti-Money Laundering (AML) are willing to follow the guidance diligently and stay on the right side of your regulators and law enforcement.
Hopefully, “that’s me” I hear you all shout in unison! For those who didn’t shout and perhaps some of those who did; is accidental (or perhaps slightly more on purpose) non-compliance presenting a real risk to you and your practice?
For me, a key part of this year will be trying to stress the benefit of AMLCC as a risk management tool rather than it being seen by some as purely a box ticking exercise that they reluctantly do.
In my simple mind I see compliance and risk management as a two parallel processes with a common outcome. The outcome being to protect yourself and your practice from regulatory and legal repercussions. If I know that the speed limit on a UK motorway is 70 mph there is a thought process that I would undertake to determine if 70 mph was an appropriate speed to travel. Is it raining, is it foggy, is there snow on the road, are simple examples of reasons why I may choose to put management of the risk to me and to others of travelling at 70 mph to the front of my mind and drop my speed to say 50 mph.
From my experience and with the benefit of discussing this topic with a large number of accountants and bookkeepers around the UK during many CPD sessions; it is fairly clear to me that virtually all professionals in our sector are clear on the general principles of what is legal and illegal, right and wrong, moral and immoral.
So, in very simple terms as money laundering relates to the proceeds of any crime in the UK or in fact around the World, we should all be pretty clear on what we’re looking out for.
The real risk of being involved in actually laundering the proceeds of crime yourselves cannot be ignored within your day to day operations. Good systems will help to demonstrate compliance while a common and professional sense approach to what is right and wrong will work together with compliance to protect and defend your practice.
I hope to have the chance to explore these risks in more detail in the future.
Please don’t forget that AMLCC is available to all AIA members in practice in the UK within their practicing certificate fee.