AML Complete Update: Supporting Independent Reviews and Risk Monitoring

The regulatory landscape for the bookkeeping and accountancy profession continues
to evolve. As previously communicated, anti-money laundering supervision across the
sector is expected to move towards greater consistency and scrutiny as the Financial
Conduct Authority develops its future supervisory approach.

In this environment, it is increasingly important for practices to ensure that their AML
controls, policies and procedures are not only documented, but are regularly reviewed
and operating effectively in practice.
As part of the IAB’s ongoing support for members, AML Complete is being updated to
further support the principles of continuous improvement and independent review
within member practices.

New questions within AML Complete

You will shortly notice the introduction of several additional questions within the AML
Complete system designed to help practices record when key elements of their AML
framework have been independently assessed.

These questions relate to:

• When the practice AML policy was most recently independently assessed and
  approved as effective
• When procedures relating to client risk assessment, PEP identification, onboarding
  and CDD, client anonymity, record keeping and SAR processes were most recently
  independently assessed
• When procedures relating to client activity monitoring and unusual transactions were
  most recently independently assessed
• When procedures relating to ongoing monitoring and review of AML compliance within
  the practice were most recently independently assessed
• When the practice policy on identifying and controlling proliferation financing risk was
  most recently independently assessed
• Members may also notice refinements to how AML Complete evaluates certain risk
  indicators within the system, supporting a more structured approach to assessing the
  strength of a practice’s AML framework.

These updates do not introduce new regulatory requirements, but they are designed to
help practices demonstrate that their AML policies and procedures remain robust,
effective and appropriate as regulatory expectations continue to develop.

The IAB will continue to support members with practical guidance and tools to help
maintain strong AML compliance now and in the future.

The Institute of Accountants and Bookkeepers