Introduction to AML in the UK

Introduction to AML in the UK

Accountants in the UK are covered by the following anti-money laundering legislation,

The 2017 Regulations replace the Money Laundering Regulations 2007 and transpose, in the UK, Directive (EU) 2015/489 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (the 4th EU Anti-Money Laundering Directive)

The anti-money laundering legislation imposes requirements on 'relevant persons' including accountants, in relation to:

  • Identification and record-keeping procedures;
  • Reporting;
  • Registration and supervision;
  • Offences.

While many of the obligations imposed on practitioners have not been significantly altered by the introduction of the 2017 Regulations, there are some new developments arising from the 2017 Regulations including:

  • Firms are now required to complete a whole firm risk assessment;
  • Firms are now required to establish some specific internal controls in relation to anti-money laundering;
  • There are changes to the requirements relating to customer due diligence which need careful attention;
  • Domestic Politically Exposed Persons (PEPs) are to be subjected to prescribed due diligence processes. The Financial Conduct Authority has published guidance on the treatment of PEPs.

The reporting obligations on ‘relevant persons’ also extend to activities relating to terrorist funds, which include funds that are likely to be used for terrorism, as well as the proceeds of terrorism under the Terrorism Act, 2000 (as amended).

The Consultative Committee of Accountancy Bodies ('CCAB') has updated it’s Anti-Money Laundering Guidance ('AML') for the Accountancy Sector in the UK.  That guidance is subject to approval by Her Majesty’s Treasury (‘HMT’) and is therefore described as draft guidance pending that approval.  The CCAB Guidance is available here.

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