Financial Crime World

Here is the converted article in Markdown format:

ACCA Member Firm’s AML Compliance Checklist

===========================================

A recent review of the anti-money laundering (AML) practices at [Firm Name], a member of the Association of Chartered Certified Accountants (ACCA), has raised concerns about several aspects of its AML compliance. The following checklist provides an overview of the firm’s current AML procedures and identifies areas that require improvement.

Compliance with AML Regulations

  • The review found that [Firm Name] does not have a formal process for employees to document and report suspicious activity, although an internal SAR form is completed and submitted to the Money Laundering Reporting Officer (MLRO).
  • The firm’s AML policy and procedures do outline this process.

Employee Training and Awareness

  • Only some relevant employees have received formal AML training, which does not cover all required topics.
  • The MLRO has not conducted an annual report on AML activities.
  • On-the-job training is not considered formal AML training, and records of such training are not kept.

Client Due Diligence

  • The firm’s customer due diligence process includes a Know Your Client form, but it does not verify the source of wealth and/or funds for high-risk clients.
  • Adverse media checks are also not conducted.

Ongoing Monitoring and Risk Assessment

  • The firm reviews existing client records as part of ongoing monitoring, but only some risk factors are considered when assessing clients.
  • A formalized risk assessment process is lacking.

Independent Audit Function

  • An independent assessment of the firm’s AML controls has not been conducted in recent years.
  • While an internal audit function exists, it does not meet the requirements for independence specified by ACCA.

Beneficial Ownership and Management Structure

  • The firm has not notified ACCA of any beneficial owners, officers, or managers who are not affiliated with the organization.

Action Required

To address these concerns, [Firm Name] must take immediate action to:

  1. Develop a formal process for employees to document and report suspicious activity.
  2. Provide all relevant employees with formal AML training that covers all required topics.
  3. Conduct an annual MLRO report on AML activities.
  4. Verify the source of wealth and/or funds for high-risk clients and conduct adverse media checks.
  5. Formalize a risk assessment process and consider all risk factors when assessing clients.
  6. Conduct an independent assessment of AML controls.
  7. Notify ACCA of any beneficial owners, officers, or managers who are not affiliated with the organization.

Completion Details

  • Completed by: [Name]
  • Date: [Date]