• Accountants and Bookkeepers

    Some services provided by accountants and bookkeepers are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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Accountants and Bookkeepers

What are the ML/TF Risks?

Some services provided by Accountants and Bookkeepers may be attractive to criminals seeking access to the financial system so they can avoid detection or raising red flags.

Professional services may also have become more attractive to criminals over the past few years as the financial sector has implemented comprehensive AML/CFT measures.

The services offered by accountants and bookkeepers that are vulnerable to money laundering activities relate to their involvement in financial transactions, such as money transfers, trust account deposits, as well as the establishment of legal entities to hold assets.

The Money Laundering and Terrorist Financing (ML/TF) risks associated with accountants and bookkeepers include:

  • Criminals may seek to conduct their financial activity through an accountant to disguise their criminal involvement;
  • Criminals may seek out accountants as gatekeepers to the financial system to give the impression of respectability and legitimacy;
  • Criminals may misuse accountants’ trust accounts for deposits or international wire transfers to avoid detection; and
  • Criminals may seek the assistance of accountants to establish companies or trusts which they use to obscure who really owns or controls the funds and assets (that is, the beneficial owner).

Accountants and bookkeepers must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/CFT laws.

What are the AML/CFT obligations?

In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:

  • Conduct a Money Laundering and Terrorism Financing Risk Assessment;
  • Develop an AML Program that is proportionate to ML/TF Risks;
  • Establish effective Board and Senior Management oversight of the AML/CFT Program;
  • Appoint an AML Compliance Officer;
  • Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
  • Implement a ML/TF Risk Awareness Training Program for staff;
  • Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
  • Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
  • Establish Record-keeping controls; and
  • Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for the accounting and bookkeeping industry.

Our solutions deliver all the foundational AML/CFT materials including a ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.

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