Risk Outlook (updated) - Circumstances where there may be high risk of money laundering, terrorist financing or proliferation financing in the accountancy sector

Both Irish and UK AML legislation requires firms to take the appropriate steps to identify and assess the risk that they could be used for money laundering and terrorist financing, and in the UK, also proliferation financing.

The Accountancy AML Supervisors Group (AASG) in the UK has recently updated its Risk Outlook Guidance which identifies those circumstances where there might be a high risk of money laundering, terrorist financing or proliferation financing in the accountancy sector. (Although drafted pursuant to UK AML legislation, many of the risks are also relevant in Ireland.)

This Guidance has been updated to include risks associated with the following:

• Complex supply chains
• Crypto
• Register of Overseas Entity verification
• Services subject to trade sanctions
• Proliferation financing
• Contractors or agency workers paid by umbrella companies