AML Complete is firstly a record of information about your practice. This is based on different ‘profiles’ which describe your practice, its ownership and structure, the staff (including contracted agents) whose work may be relevant to anti money laundering and the services offered. It also covers the Practice clients, their business type, ownership, and structure. AML Complete uses all this information to calculate and highlight AML compliance and relevant risks affecting the practice and displays alerts and key information in a ‘dashboard’ format.

AML Complete provides a database of information around AML Risk for IAB. This is not only focused on individual bookkeeping or accountancy practice but, for example, also aggregates information about the services being provided collectively across all IAB Members or the different types of client businesses being served by Members. This broad overview enables IAB to identify useful industry best practice including AML risk issues that may benefit from specialist advice or guidance. The system also provides an effective method for users to share AML relevant documents with IAB Although it’s important to note that not every uploaded document is immediately reviewed. Where necessary IAB may sample documents to assess an individual practice or to identify themes, broad issues or gaps that may point a need to develop training input or circulate guidance that will benefit all members.

Access to AML Complete is restricted only to IAB Supervised members. AML Complete accounts also require a current IAB Supervised membership. Presently the system is configured for one account holder per practice. Arrangements to accredit additional users are under development.

The identifying details for each AML Complete account are drawn automatically from IAB Membership data and cannot be adjusted from within AML Complete.

AML Complete is being rolled out over 2023. An AML Complete account will become available to each AML Supervised IAB Member. Initially only that member will be able to log-in to AML Complete. A process to enable AML Complete account holders to apply for additional log-in credentials for their practice employees will be introduced in due course.

This button becomes active once all the profile questions have been answered. Clicking the ‘complete’ button initiates a transfer of that profile information to IAB.

AML Complete is designed to help you manage AML for your practice. The ‘Dashboard’ is intended to highlight areas where there may be some AML Risk or where there is a risk the Practice is non-compliant with the money laundering regulations (MLTF). The user should review the highlighted issue, take action and then update AML Complete. For example; AML Complete will indicate a non-compliance risk affecting the Practice where staff training is not current. Once the relevant staff member has refreshed their AML training AML Complete should be updated and a copy of their current training certificate uploaded.

Presently, document uploads are available in response to certain profile questions. This provides a facility to share a specific document with IAB. AML Complete does not currently provide a general document storage service.

AML Complete includes provision to upload a document. This facility is available against certain AML relevant topics (for example AML Policy) Acceptable file types are restricted to ‘Portable Document Format’ (.pdf) files. This upload facility provides for storage of one document per topic. [NOTE] A subsequent upload will overwrite the previous document and replace it with the most recent. In some cases, where several original documents may be relevant (for example CDD documentation) a single composite .pdf document should be uploaded.

Yes. Look for the ‘download’ button. Clicking this will initiate a download of a spreadsheet containing your last ‘saved’ data.

To speed up data entry most questions within AML Complete provide three ‘tick box’ type answers, usually ‘Yes’, ‘No’, or ‘Uncertain’ The user should select the most accurate answer. Depending on the response the system may generate a further question. For example, if the answer is ‘Yes’ to the question ‘Are there any Politically Exposed Persons associated with any of the practice clients’ then a further question will appear asking whether a senior manager of the bookkeeping or accountancy practice has specifically approved this client.

In short because all the questions apply to some aspect of risk or compliance. AML Complete is designed to cover the AML compliance issues relevant to your Bookkeeping or Accountancy practice. Each question examines a specific issue. Where something may not apply (for example in relation to Practice clients involving Politically Exposed Persons) the system has been designed to generate additional questions to clarify the answer.

Where necessary information is not immediately available AML Complete provides the option to answer ‘Uncertain’ in response to some questions. However, this answer will usually induce the system to produce an elevated ‘risk’ or ‘compliance’ rating and users should endeavour to confirm and update the information as soon as practicable.

Whilst in the process of entering data clicking the ‘save’ button will save your work up to that point. If the profile you were working on is incomplete you will be able to return to that profile later to continue where you left off.

No. One of the benefits of AML Complete is that, once your account has been set up and populated with your data only changes and updates will be necessary. For example, if you retain the same clients year on year only relevant changes will need to be made on that profile: things like updates on their risk assessment, the services you provide to that client etc.

No, it is included with your AML Supervision licence.

CONTENT

Practice Profile

The Practice profile is the first part of AML Complete you will create. The Practice Profile is populated with information about your bookkeeping or accountancy business. You will input details including the structure of the business, beneficial ownership, the services offered etc. AML Complete will also invite you to upload copies of AML relevant documents which will be stored on the system and accessible to IAB. [NOTE: Documents uploaded on AML Complete are restricted to ‘Portable Document Format’ (.pdf) files]

Beneficial Owner Profile (Client business)

A Beneficial Owner profile is needed for each client business, identifying the structure and ownership of that business.

Client Profile

A Client profile is needed for each client business. This profile will include details about the owner(s) of the client business, what that business does, it’s structure, how it interacts with its customers and wider information to assess the AML Risk that may be generated.

Contractors Profile

A Contractor (or agent) Profile is needed for each person contracted by the practice carrying out AML relevant work. For example, someone who does ‘outsourced’ work from time to time.

Staff Profile

A Staff profile is needed for each person employed doing AML relevant work for the Practice (including the owner) This profile will include their details and information including their updated AML Training.

AML Complete is part of the process IAB uses for its statutory AML Supervision. It is a condition of use that the information entered by users is accurate, complete and up to date.

Although some practices have many clients most IAB Supervised members provide services for a relatively small number. A facility to enable uploading client details using CSV formatted data will be introduced in due course.

ANTI MONEY LAUNDERING

The Consultative Committee for Accountancy Bodies publishes, and regularly updates, comprehensive industry guidance on the UK Money Laundering Regulations and how these regulations should be applied in practice by Bookkeepers and Accountants. (The use of this guidance within AML Complete is by kind permission of CCAB) the guidance document is available here: https://www.ccab.org.uk/wp-content/uploads/2020/09/AMLGuidance2020.pdf

Based on the information entered on the system by the user AML Complete includes a facility to produce a documented summary of AML risks related to the practice.

IAB is a ‘Professional Body Supervisor’ (PBS) Under the MLTF Regulations 2017 and 220 IAB. As such IAB uses information relating to bookkeeping and accountancy practices for the lawful purpose of supervising compliance with the Regulations. This is provided for under the General Data Protection Regulations and allows information (including personal data) to be shared.

IAB uses a combination of different methods, including remote and on-site inspections for supervision of bookkeeping and accountancy practices. AML Complete contributes to that process as a source of data relevant to AML risks and the overall compliance with MLTF Regulations. It is not designed as an inspection tool.

Visit the IAB Member’s homepage where you will find everything you need to know about AML Regulations and how to comply.

We also have a number of AML courses to help you comply with AML regulations. As a member you receive Modules 1 & 8 for free! Discounts are available on the six remaining modules and additional CPD courses to help improve your knowledge!