The CPAA is pleased to add more support to its AML armoury, with the launch of a new helpline. Available 24/7, members can gain access to advice and guidance bespoke to specific queries or issues from a specialist consultancy led by Ian Waters MA FCA.
An expert in the field of compliance and a qualified Chartered Accountant, Ian has significant experience in both the practice and regulatory sides of the profession. His credentials include being the former Director of Professional Standards at the Institute of Financial Accountants and Head of Standards at the Association of Chartered Certified Accountants.
Ian is now Director of Compliance for Accountants, which will support members with this valuable new facility that forms part of the CPAA’s suite of AML services and tools. Here, Ian explains more about the new helpline, what to expect, and the support it can provide.
How can I access the helpline?
In the first instance, get in touch via email. Outline your query and send it to aml@cpaa.co.uk. The helpline is monitored by a dedicated member of staff during office hours, and we respond to all enquiries as soon as possible.
You will receive an initial response within 2-3 working days. If a more extensive response is needed, it will follow within 15 working days, and usually much sooner. In some cases, you will be asked for your availability to discuss the issue in greater depth. Naturally, the advice provided must be based on the most accurate information available.
Why use the helpline?
This new service supports CPAA members – alongside and in addition to the content in the Members Area of the CPAA Zone. It goes a step further; providing guidance, reassurance, and an opportunity to get specialist advice tailored to your needs.
When facing uncertainty in any area of professional standards and compliance, consultation with a specialist is a fundamental safeguard. If an enquiry results in a telephone call to discuss the matter in more detail, the call will be followed up with an email summarising the advice given. This all helps to demonstrate that a member has taken appropriate steps to resolve a professional or ethical issue.
What can the helpline support me with?
Small practices, in particular, often take the view that small businesses and long-standing clients present little AML risk. However, small businesses will often have cash-based transactions; they may find themselves under financial pressure; the records they keep may not be in good order; or they may be part of a complex supply chain. There are many reasons why a client risk assessment may not be straightforward. This may warrant seeking expert advice.
Practitioners might also be unfamiliar with the process of recognising and reporting suspicion of money laundering. This could give rise to an unconscious bias against reporting to the NCA. Having access to a dedicated helpline will help to address any bias and so safeguard the practitioner by helping them to file a suspicious activity report (SAR) as and when appropriate. We urge practitioners to use the helpline to guide them through any areas of uncertainty.
A practitioner is likely to recognise when they have concerns regarding SARs or client onboarding, such as risk assessment, due diligence and verification work. Yet they may be less likely to recognise that they need support in the practice-wide aspects of AML compliance, for instance AML policies and controls, the assessment of practice-wide AML risk, and the conduct of regular AML compliance reviews. The helpline can also be useful in answering questions practices may have after a visit – and any subsequent feedback or criticisms – from their AML supervisor.
By the way, apart from AML queries, the helpline can help to address issues relating to other areas of professional standards and compliance. For example, a member may be unclear about their obligations under the CPAA Rules and Byelaws, or unsure about how to address an ethical dilemma.
How are regulations changing?
Recent amendments have been made to the Money Laundering Regulations and practices need to stay up to speed with developments. These include changes relating to the registration of trusts, ‘proliferation financing’, the reporting of material discrepancies in the relevant registers (including the Register of Overseas Entities), and the power of a supervisory authority to require copies of SARs made to the NCA.
Given the introduction of references to ‘proliferation financing’ throughout the Money Laundering Regulations, members may like to know that the rather lengthy definition of ‘proliferation financing’ is to be found in regulation 16A. It is important because it is more relevant to the work of accountants than one might assume. Practitioners must be able to recognise the risks where a small business may be playing a role in a much larger operation.
Firms must ensure they know as much as reasonably possible about the business of their client. Could the goods being manufactured, shipped or financed by the client be used (in whole or in part) in connection with chemical, biological, radiological or nuclear weapons? For example, a firm should know what the client is shipping, the final destination of the relevant goods, how the goods supplied might be used as components, and whether the goods could be ‘dual use goods’ - capable of being used in a way that may not be immediately apparent.
What other AML hot topics should I be aware of?
Another significant development over recent years is the greater emphasis now being placed on financial sanctions since the Russian invasion of Ukraine. If a client were to breach those sanctions, it would almost certainly give rise to a financial benefit, i.e. the proceeds of crime.
Additionally, the Government is yet to determine the outcome of the recent consultation regarding the future supervisory framework for AML compliance. Whatever the outcome, we can be sure of two things. Firstly, it will take some years to pass any legislation required for significant changes. Secondly, in the meantime (and subsequently), pressure will continue to be placed on supervisory authorities to enforce compliance to a consistently high and robust standard.
What other AML support is there?
Maintaining compliance with the Money Laundering Regulations can prove challenging for many practitioners, most of whom want to get things right. The CPAA provides comprehensive guidance to support members in AML compliance. These include tools and services designed by industry experts. Through the Members Area of CPAA Zone, all members have access to a unique support package which consists of a compressive guide designed for practitioners and a collection of checklists and templates which can be customised according to the member's circumstances.
CPAA Zone and the CPD programme offer comprehensive training, led by industry experts. Live sessions enable members to directly ask specialists any questions they may have on AML/CTF compliance. The purpose of the helpline isn’t to act as a training resource, but there are plenty of routes and resources for members to gain knowledge and skills in this area.
The new helpline completes the picture; the CPAA now provides members with a fully rounded suite of tools, templates, training and tailored support. Explore all that is on offer to put your practice in the best position for the year ahead.