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.