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Changes to our Anti-Money Laundering Procedures Manual

It is vital for all accountants to manage their compliance obligations under the anti-money laundering and terrorist financing regulations correctly. Insufficient procedures can result in problems with your supervisory body, unnecessary stress and ultimately the senior management of firm committing a criminal offence.  Going to the other extreme and implementing procedures which are unnecessary for the size and risk profile of your firm can be expensive and inconvenience clients.

We were delighted earlier this week to release our new Anti-Money Laundering Procedures Manual which is written to allow most firms to adopt it as their own procedures with minimal tailoring. This Manual builds on the 2017 Regulations and the draft Guidance from the CCAB and we have worked hard to ensure the Manual is fully compliant but also deals with these issues in a practical way. Existing users should find the documentation simpler and easier to follow than before.

A key change in the new Regulations is for the firm's senior management to be proactive in designing the firm's procedures and in assessing how these work in practice. Therefore the major changes to the Manual deal with the annual compliance review process. Its important that your MLRO familiarises themselves with this.

Another key message is the need to assess the training needs of staff and subcontractors and to ensure regular training takes place which is relevant to their role. Don't forget that HAT provides courses covering the topic generally and reporting in particular. An overview of the changes is also available in our current CPD Update.