Are you confident your firm complies with Clients’ Money Regulations that came into force on 1 January 2017?
The ICAEW’s advice is ‘if in doubt, seek advice’. Would your firm benefit from an impartial perspective to highlight issues to be resolved before they becoming problems?

A Client Money Compliance Review would save partner time and give you peace of mind, removing any doubt. It would ensure that:

  • Bank accounts have been set up appropriately.
  • Records kept are sufficient to meet the requirements of the rules.
  • Appropriate checks including AML were carried out for a sample of clients where client money is held.
  • Client money been put in a designated account where required.
  • The treatment of interest is appropriate.
  • For sole practitioners, appropriate safeguards are in place.

What is the impact of non compliance?

  • If the client account has not been properly set up not only will it breach regulations, but also put your client’s money at risk.
  • Failure to keep appropriate records, could risk funds inappropriately being paid out and the firm liable to replace those funds.
  • Failing to perform appropriate checks could lead to the firm inadvertently being involved in illegal activity. Which could lead to criminal proceedings.
  • Breaching regulations, if highlighted by the regulators, could result in sanctions. The ICAEW’s sanction has a starting point of £1,000.

Who might benefit?

Larger firms where there are multiple teams/staff, non – audit firms and firms with significant amounts of client money.

If you have already identified/suspected issues, a review will advise you on the action required to resolve the issues.

How much does it cost?

The standard assignment would be chargeable at £995 + VAT for members and  £1300 + VAT for non members and typically take half a day either on site or, where records can made available securely, remotely.

A written summary of the findings and recommendations will be provided. Should additional procedures or discussion be requested where specific issues exist a tailored assignment could be agreed.

This review could also be undertaken as part of an annual compliance review.