It seems that the life of a sole practitioner becomes ever more complicated with scores of regulations to follow every year. One set of rules that stand out are those related to anti money laundering. Although these rules have been around for a considerable amount of time, recent reports highlight that a significant number of accountants are falling foul of the regulations – see in particular the Accounting Web article from Philip Fisher which claimed that:
Over a third of accountants fail in AML compliance
Accounting Web article from Philip Fisher
Is failure a surprise?
For anyone who has tried to wade through the guidance in this area it may not be a surprise that so many accountants are falling foul of AML compliance. A sole practitioner can be forgiven for feeling overwhelmed by the masses of guidance as well as numerous courses available on the subject. Amongst all other practice responsibilities, devoting time to Anti-Money Laundering and Counter-Terrorist Financing can leave the sole practitioner feeling rather swamped.
Sole Practitioner Approach
Ideally a sole practitioner needs something on this very important topic which is tailored and specific to them.
Something that cuts through the myriad of information covering organisations of every size. Something that they can pick up, work through, learn and implement very quickly.
Our “Create a Money Laundering Policy For Your Practice” course does just that.
CCAB Guidance
The course has the CCAB guidance at its heart.
This guidance covers everything to do with Anti-Money Laundering and Counter-Terrorist Financing in the Accountancy Sector albeit there is no market segmentation within the CCAB’s 140 page plus document. It covers the whole accountancy sector regardless of size of practice. That’s a lot of reading to do to wield out the bits which apply to the sole practitioner.
Regulation regulation regulation
There’s no doubt that regulation is needed to prevent or at least spot money laundering or counter terrorist financing activities. However regulation needs to be practical and suitable for those that are tasked with implementing it.
Regulation needs to be fit for purpose.
That’s why SolePrac.co.uk has developed a course specifically for sole practitioner accountants, bookkeepers and tax advisors with the end result being a Money Laundering Policy fit for your practice.
As part of completing the course the sole practitioner is lead through the important aspects of the money laundering and counter-terrorist financing regulations that they need to understand. That knowledge is taken onto the task of developing the processes, procedures and checklists that can be used in the sole practitioner’s own practice, based upon suitable templates provided. This ensures that money laundering or counter terrorist financing activities are considered in every aspect of the sole practitioner’s operation from the pre-sales process through to client acquisition and onboarding process and annual reviews.
Compliance and Practice Assurance
Simply put, this course does the hard work for you and provides the collateral that you need to use for compliance with the legislation and, of course, any practice assurance visits that you may need to undertake.
Verifiable CPD
The course also provides you with 150 minutes of verifiable CPD which counts towards your targets for the year. The final chapter of the course gives you text to use in your CPD log and on completion of the course you will receive a completion certificate as evidence to back this up.
Course Contents
The course content is vast but it’s easy to undertake as it is broken down into chapters and then lessons. Our learning management solution, Thinkific, allows you to work through each lesson and chapter at your own pace marking it off as you complete it; so you know exactly where you are at.
You don’t have to do it all in one go – you can work on it over a period of time. In fact we recommend that you do just that perhaps dedicating small periods of time to the course each day until completion. When you come back to the course you can see what you have completed and where you are up to. And of course the content is there for you to refer to in the future.
As well as the course content there are tasks for you to undertake as part of your learning which helps you to arrive at your completed money laundering policy for your practice.
The course content is comprehensive …..
- Introduction
- Who this course if for
- MLTPF Explained
- Research Undertaken
- Recommended Reading
- What is in scope?
- Money Laundering advice specific for Sole Practitioners from the Professional Bodies
- The responsibility of a sole practitioner
- Inconsistent practice assurance review outputs
- Accounting is historical
- GDPR v ML v Tipping Off
- Knowing Our Clients
- Defining Money Laundering and Terrorist Financing (MLTF)
- Introduction
- A Crime or Proceeds of Crime
- What is terrorism?
- Property defined
- What is a Primary Offence
- Failure to Report Offence
- Tipping Off Offence
- Prejudicing an Investigation offence
- Proliferation Financing (PF) Definition
- General Guidance
- The responsibilities of MLTPF for a Sole Practitioner
- Beneficial Owners, Officers and Managers (BOOMs)
- Who is a BOOM?
- Policies, procedures and controls required
- Risk of proliferation financing
- Annual Client Review
- Risk based approach for Sole Practitioners
- Practicalities
- Assessing Risk
- Service Provision
- Specific Target clients
- Clients to avoid
- Client Products and Service Provision by Sole Practitioners
- Client business structure and geographical location
- Delivery Channel
- Existing clients
- Client acquisition
- Overall Risk Profile
- Future Changes
- Customer Due Diligence
- Undertaking customer due diligence
- Application of customer due diligence
- Simplified due diligence
- EDD, PEPs, financial sanctions and other prohibited relationships
- Reliance on third parties
- Third party supplier
- Evidence gathering
- If CDD cannot be undertaken
- Cessation of work and suspicious activity reporting
- Discrepancies in the People with Significant Control Register
- Reporting a discrepancy
- What is a material discrepancy?
- When should a material discrepancy be reported?
- Material discrepancy and a SAR
- Practical application
- Suspicious Activity Reporting
- What is a suspicion?
- Tipping Off Risks
- Prejudicing an Investigation
- Confidentiality
- Documentation
- What happens after a SAR has been made?
- The Client Relationship
- Data Protection
- Requests arising from a change of professional adviser (professional enquiries)
- Other requests for information
- Reporting to other bodies
- Record Keeping and Training
- Record Keeping
- Training and Awareness
- Processes and Forms
- Pre-Sales Process
- Client Acquisition and Onboarding Process
- Annual Review including existing client review for new legislation
- Processes and Forms Appendices
- Pre-Sales Qualification Checklist
- Client Onboarding Checklist
- Client Information Form
- Annual Review Checklist